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.



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