The payment initiation service is – subject to any exceptions – a payment service that requires a licence. According to Section 1 para. 1 sentence 2 no. 7 of the German Payment Services Supervision Act (ZAG) in connection with Section 1 para. 33 ZAG the term “payment initiation service” refers to services whereby a payment order is triggered at the request of the payment service user with respect to a payment account with another payment service provider.
Payment initiation services have become subject to a licence and supervision for the first time under the Second Payment Services Directive. This was done to address the development of new technologies, particularly in the area of electronic business and payment transactions. Over the past few years, service providers have emerged in this area which enable access to the payment account of payment service users in order to initiate payments via credit transfers on the Internet. At the same time, these service providers are able to provide the payee with timely assurance that the payment order has been transmitted.
The payee can therefore be prompted to release the relevant goods or render the relevant service immediately (BT-Drucks. 18/11495, p. 107). The payment initiation service is described in more detail in the BaFin’s guidance note (Hinweise zum Zahlungsdiensteaufsichtsgesetz (ZAG) dated 22/12/2011, as amended on 29/11/2017 at item 2. f)).