PSD3 and PSR: Where Do Exemptions Apply? | ALLES LEGAL #107

🎧Which companies will need regulation – and which won’t? In Episode 107 of Alles Legal – Fintech-Recht kompakt, Peter Frey explains who falls under PSD3 and PSR – and where exemptions apply. Tune in now!

New Rules, New Obligations – What Changes Under PSD3 and PSR?

In this episode, Peter Frey, lawyer and partner at Annerton in Frankfurt and author at PayTechLaw, joins host Dana Wondra from Payment & Banking to discuss the scope and implications of the new PSD3 Directive and the Payment Services Regulation (PSR).

Who Will Be Covered?

  • PSD3 remains focused on payment institutions
  • PSR also applies to banks, technical service providers, and system operators
  • E-money institutions will be treated as payment institutions
  • Providers of electronic communication services may now be included

Exemptions – Old and New

  • Existing exemptions like agents or voucher systems remain
  • Group exemption expanded to include external intra-group transactions
  • New: Retail cash withdrawals up to €150 without prior purchase

Registration Instead of Licensing

  • Account information services remain subject to registration
  • Independent ATM operators will now require registration

Collision With MiCAR: Double Regulation Ahead?

  • E-money tokens will fall under PSD3/PSR
  • Some exceptions are defined but remain complex
  • Crypto service providers may face additional hurdles

Next Episode Preview

Episode 108 will cover new liability rules, protections against social engineering, and shifting security responsibilities.

About this podcast

Alles Legal – Fintech Recht Kompakt delivers sharp, weekly insights into legal and compliance matters in the world of banking. (in German only)
This podcast is a collaboration between Payment & Banking and PayTechLaw.
Each Wednesday, we unpack the legal developments shaping the financial world – clearly, concisely, and without the legal jargon.
Since 2021, PayTechLaw authors and Annerton attorneys have brought depth and clarity to complex topics.
Whether it’s PSD3, DORA, or FiDA – we provide the legal context you need.
In 20 minutes. No detours.



By continuing, you accept our privacy policy.
You May Also Like
FIDA: Finanzinformationsdienstleister, Gatekeeper & Rechtsvertreter in der EU | ALLES LEGAL #119
Read More

FIDA: Financial Information Service Providers, Gatekeepers & Legal Representatives in the EU | ALLES LEGAL #119

In this episode of “Alles Legal – Fintech-Recht kompakt”, Annerton lawyer Awet Yohannes explains the new role of Financial Information Service Providers (FISPs) in the EU’s open finance ecosystem. Together with Dana Wondra, he discusses the authorisation requirements, regulatory obligations, and the controversial debate around whether gatekeepers like Apple or Meta should be excluded.
Read More