Comment on reporting obligations for payment service providers
Comment from TechSverige:
The reporting obligation is set at 26 transfers per quarter to a given recipient. However, there is no reporting obligation linked to amounts. As this is obviously based on previous EU directives, it cannot be influenced in the proposed regulation but risks becoming a toothless regulation.
The privacy aspects of the information on individuals and businesses that the proposed database will handle are difficult to assess as it does not yet exist. Where will the database be located? How will transfers between countries and the database be protected, and how will access to the information in the database be protected? These questions have recently become central. Given that all EU members are to participate in this network, the security analysis seems somewhat incomplete.
Nils Weidstam
Industrial policy expert