ECJ Clarifies the Scope of PSD2: Not Every Transfer of Third-Party Funds Constitutes a Payment Service
The ECJ has further clarified the distinction between payment services and other business models. The judgment confirms that merely receiving and forwarding third-party funds does not automatically trigger licensing requirements under PSD2. The decision provides greater legal certainty for FinTechs, platform operators and other businesses handling payment flows, while emphasising that the specific business model remains decisive.