Irish Payments Industry Response to the New Legal Framework for Payments (NLFP)
IPSO is the representative industry body for the Irish payments industry and the strategic interface with all payments stakeholders. IPSO engaged Bayberry to prepare the industry’s response to the European Commission’s consultation on the New Legal Framework for Payments. The response was submitted to the European Banking Federation (FBE) in its capacity as “pen-holder” for the European Payments Council (EPC). The EPC collated extracts and concepts from the response for incorporation into a consolidated response from the European banking industry, which in turn was provided to the European Commission.
The Objective
The New Legal Framework for Payments (NLFP) was a proposed legislative framework intended to be an initial step in the overall SEPA (Single Euro Payment Area) vision. IPSO required assistance to assess and respond to the consultative document from the European Commission on behalf of the Irish banking community. The response was to take place during an intensive month-long engagement to meet the required deadline.
IPSO requested assistance from consultants who could relate proposed EU legislation to the operation of payments systems, and who could conduct detailed interviews with senior executive stakeholders.
Our Approach
We provided regulation and payment operations expertise and a structured methodology to conduct this intensive engagement against a pressing deadline. We examined the New Legal Framework’s proposals and identified key areas of debate that we assessed would impact banking payments operations. We interviewed senior executives from the membership of IPSO to establish the impact and viewpoints on each aspect of the consultation paper.
The Outcome
An important outcome of our engagement was the identification of how the NLFP would impact the Irish payments industry. These impacting factors could have undermined the objective of the NLFP for a level playing field across the EU payments industry.
We assimilated all responses from industry executives along with our own analysis of the NLFP and recommended provisions, to create a response to the European Commission’s consultation process.
The key representatives of the Irish banks were briefed on the impact of the New Legal Framework for Payments and their views were represented in IPSO’s response to the consultation.
