Entries by Dr. Hugo Godschalk

Open CESOP: The Commission’s new data collection frenzy

First, the bad news:  The Commission has again looked more closely into cross-border (or more simply “XB”) payments in the EU. It is planning a supranational database known as “CESOP” (“Central Electronic System of Payment Information”) under its supervision. From January 2022, XB payment data of all payment service providers (credit institutions, payment and e-money […]

Ephemeral e-money

E-money is booming, at least in Europe. Never before have the central banks counted as many e-money transactions as in 2017. In some member states the competent authorities are inundated with registration applications from e-money institutions (EMIs). Now that registrations in the UK are no longer as attractive (but despite Brexit, around 40% of European […]

Reg. 924: Not just bad news for card issuers

The Commission already presented its proposal to amend and thereby extend the Pricing Regulation EC 924/2009 (in short: Reg. 924) in March 2018. The two main topics the proposal addresses are: price transparency regarding currency conversions of payments at the POS or ATM (keyword DCC – Dynamic Currency Conversion) and price equality for cross-border payments […]

Right to anonymous payments

Do we have a right to anonymous payments? If so, is this right linked to certain payment instruments, such as cash? Does this right apply equally to payers in the analogue and the digital world? For most people, the daily payments initiated as market participants are unavoidable. It has therefore become one of our basic […]

Interchange Fee Regulation: gender-specific universal cards

The current debate concerning gender-political correctness would appear to suggest that there are not just women and men but many different variants in between. One variant is the circumstantial or time-dependent dominance of the respective gender of a human being. Terms like bi-gender, gender-fluid or simply gender-queer try to describe the phenomenon. It may come […]

Regulation 924: The new populist trend towards an EU pricing regulation

At the end of March 2018, the European Commission published a proposal to amend Pricing Regulation 924/2009 regarding cross-border payment charges (Regulation 924). Christian Walz has already discussed the proposals contained therein for the regulation of dynamic currency conversions (DCC) as part of this blog. Regulation 924: Not just dynamic currency conversion The Commission’s proposal […]

E-Loyalty: To be or not to be

E-Loyalty: Multi-partner bonus programs under review from a ZAG perspective Since 13 January 2018 the new payment services directive (PSD2) also applies in Germany as a result of changes to the ZAG and the BGB. The new BaFin guidance note regarding the ZAG contains a lot of information regarding the implementation of the directive in […]