Regulatory Evolution of AISP and PISP: New Regulations and Their Impact on the Financial Sector

In the dynamic world of digital financial services, Account Information Service Providers (AISP) and Payment Initiation Service Providers (PISP) have emerged as key players. Recently, a series of new European regulations have refined the regulatory framework governing these entities. Let’s analyze how these changes affect the landscape of digital financial services.

1. Implementing Regulation (EU) 2017/1110

This regulation establishes technical standards for the authorization of data supply service providers, including AISP and PISP. Key changes include:

• Standardization of forms: Standardized form models and templates are introduced for the authorization application, simplifying and streamlining the process for new providers.
• Notification procedures: Clear procedures are established for notifications related to changes in the information provided during the authorization process.
• Greater transparency: National regulators will have a clearer and more uniform view of providers operating in the market.

2. Delegated Regulation (EU) 2017/577

Although this regulation primarily focuses on financial instrument markets, it has indirect implications for AISP and PISP:

• Volume limitation mechanism: This could indirectly affect PISP by influencing how certain financial transactions are processed and reported.
• Transparency requirements: AISP could be affected by new information requirements, especially if they provide aggregated data that includes information on financial instruments.

3. Delegated Regulation (EU) 2017/571

This regulation is particularly relevant for AISP and PISP, as it establishes:

• Authorization requirements: Specific criteria that data supply service providers must meet to obtain and maintain their authorization are detailed.
• Organizational requirements: Clear rules are established on the organizational structure, governance systems, and internal controls that these providers must implement.
• Publication of operations: Requirements for the publication of information on operations are defined, increasing market transparency.

4. Delegated Regulation (EU) 2017/565

This regulation complements the MiFID II Directive and, although it focuses on investment service firms, it has implications for AISP and PISP:

• More precise definitions: Key terms are clarified, which may affect how certain services offered by AISP and PISP are classified and regulated.
• Organizational requirements: More detailed rules on internal organization and operational procedures are established, which could serve as a reference for best practices in the AISP and PISP sector.
• Investor protection: Although it focuses on investment services, client protection principles could influence AISP and PISP practices in relation to data management and transaction security.

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5. Delegated Regulation (EU) 2017/590: Reporting of Transactions

This regulation establishes technical standards for reporting transactions to competent authorities. For AISP and PISP, this implies:

• Greater transparency: They must report in detail the transactions they initiate or about which they provide information.
• Data standardization: Specific formats are established for reporting operations, requiring adaptations in AISP and PISP systems.
• Customer identification: The mandatory use of unique identifiers for customers is introduced, affecting how AISP and PISP collect and handle user data.

6. Delegated Regulation (EU) 2017/585: Delegated Regulation (EU) 2017/585: Reference data for financial instruments

This regulation primarily affects how reference data for financial instruments is handled. For AISPs and PISPs, the implications include:

• Expansion of information scope: AISPs will need to provide more detailed information about the financial instruments associated with the accounts they manage.
• Improved interoperability: Standards are established for information exchange between financial entities, AISPs, and competent authorities.

7. Delegated Regulation (EU) 2017/580: Order data record keeping

This regulation establishes rules for keeping records of data related to orders for financial instruments. For AISPs and PISPs, this means:

• Storage requirements: They must implement robust systems to store detailed data of initiated payment orders (PISPs) or accessed account information (AISPs).
• Enhanced traceability: A detailed record of all operations is required, increasing audit and supervision capabilities.

8. Delegated Regulation (EU) 2017/574: Clock synchronization

This regulation establishes rules on the accuracy of clocks used in financial operations. For AISPs and PISPs, the implications are:

• Time synchronization: They must ensure their systems are synchronized with extreme precision, which may require investments in technological infrastructure.
• Accurate operation logging: All operations must be recorded with highly precise timestamps, affecting how transactions are logged and reported.

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