XMAS SPECIAL 2025

Michael Salmony 0:12

Hello, my name is Michael Salmony and Javier and Ralf and I would like to welcome you to another Christmas episode. You can see for our festive garb that we have commemorated the occasion. Ralf has his hat, I have my silly pullover and Javier has a beautiful Christmas beard so we're all prepared for the occasion.

Javier 0:30

If you

Michael Salmony 0:36

So what we did last Christmas episode, we made a wish list, each of us said what we really wanted from Father Christmas and we thought we would, a, review whether we got our wishes and what new wishes we have. Now, Ralf usually has the longest wish, so I suggest he starts with his wish list.

Ralf Ohlhausen 0:56

Okay, I will and so I was looking back as well. last year, I think I did start off with instant payments, which was the most imminent. And now that has come ⁓ into existence. And so I think the review there was, or the good news is that two of my three

Javier 1:19

So.

Ralf Ohlhausen 1:20

wishes on IPR instant payments actually

have come true. Well, so I'm very grateful. So it's a great start. It goes downhill from there later on, you will see. But let me start on the high note. So with instant payments, well, firstly, I think one of my biggest wishes overall last year was that banks would not be tempted to start

charging for non-instant payments so that they could avoid the surfees on instant payments. So that was a trick that I thought some banks may have up their leaves. I think there were some, not many, but just a handful or whatever occasions I heard of this. Overall, think we've seen

the introduction of instant payments coming in with no extra fees for at least for the consumer side. So I think that is fine. And I'm very grateful for that because that of course is the basis for using instant payments for payments. Otherwise, you know, people wouldn't use it if they had to charge a fee for actually making the payment itself. Now, the other one ⁓ that also came true was that the PISPs wouldn't get pulled

Javier 2:31

Okay.

Ralf Ohlhausen 2:46

too much into this whole verification of payee thing. And there was some back and forth and but overall I think we're probably good on that as it stands. There were a couple of ⁓ Q&A's as well answered by FISMA in the way that we were hoping for. So I think we're good on that. I think the one thing that did not come through on that was that banks would start

Javier 3:02

you

Ralf Ohlhausen 3:11

⁓ with not just with receiving instant payments at the beginning of the year, but also sending to just do it in one go. But no, they did wait to the very last minute basically in October to start the sending part. But anyway, so it's history ⁓ and that's done. But let me move on to PSR, which of course I had a long list last year already and it's still there. ⁓

So one of the important ones for hoping for better contingencies, don't know if that will happen. is very critical. is probably the most critical of everything. So without having contingency planned in, a fallback planned in, will, ⁓ TPPs in most of the European countries will not be able to ⁓ really make any success really there.

So this is ⁓ absolutely fundamental also for various reasons, but essentially you can't offer a service if it has single points or failures, this would not work out. And the other one is about not requiring contract rights for payers.

So because the council has come up with a strange idea that PIS would normally be a service to the payer there, which it's not. It's normally a service to the merchants. So 95 % of use cases are that way. This is how it always has been. And we can't just redefine now the rules of definition and basically pull the carpet underneath all PISPs. That would be an absolute disaster. So those two for me continue and are

probably the two biggest ones as well. There are two other ones I had

Javier 5:06

.

Ralf Ohlhausen 5:07

getting away from this concept of dedicated interfaces, which is really, really, I think one of the reasons for all the problems that we have. We shouldn't have any TPP dedicated interfaces. should have, yes, we want API-based interfaces, we want machine-to-machine, but the more stakeholders are using it, the better. So we have

Javier 5:11

. . ⁓

Ralf Ohlhausen 5:29

if we could use the same that corporates use or maybe consumer use, mobile APIs, all of that, that would be great. But having one

specifically dedicated to TPPs and then having TPPs confined to using that and only that one, that's the recipe for disaster. That is basically a monopoly situation, which we know is the enemy of quality. that ⁓

But I think I have to give up on that one. I'll come, I'll replace it with a new one because it's not looking that it's going there. ⁓ The other one, which has also not come true and I'm very unlikely now is that competition authorities would get involved because I think it was one of the reasons why we had a better situation in the UK because it was, ⁓ they had a very strong stick basically and yeah, but it's not going to happen. So

Javier 6:00

You

Ralf Ohlhausen 6:27

Therefore, let me replace it with two new ones. And the first one is about opening really the possibility for PIS to expand to the point of sales, retail, physical commerce. So we had open banking working for an e-commerce for a while, decade, two decades actually, but ⁓ making it work at the point of sale in a physical store is an additional challenge. And for that, ⁓

we have basically two things that are really required. ⁓ You need to have, because you can't do a redirect from a POS terminal, so you got to have an embedded SCA flow for that. What could also work is an app-to-app redirect. So once you are on the phone, so that is maybe a possibility. But altogether, there is this concept which we call signed payment request, which ⁓

Javier 7:11

you

Ralf Ohlhausen 7:24

Hopefully, maybe I'll put a link somewhere so people can look up. It is essentially using the proximity network in the most secure way, most end-to-end encrypted and everything. So you need a bit of bandwidth for that and you have quite some back and forth to make it really secure. That's why you can't do it by NFC or QR code. need Bluetooth for that. But that is possible and it would...

Javier 7:33

.

Ralf Ohlhausen 7:52

essentially create an alternative to EMV there in

the interaction between the POS terminal and the mobile phone. would create a really state-of-the-art modern interaction that would work also for the EUDI wallet and for whatever how much security you want to impose. It would be there. in return,

I think you would need less contracts. Everything is more open. You need less trust because it's sort of zero trust thing. So you would create much less cost ⁓ overall. And I think that would be good. Anyway, let me stop here. have come back with more.

Michael Salmony 8:32

Even more, okay, you're going to keep Santa busy, okay. But have you, maybe you want to give us at least the first parts of your wishlist.

Javier 8:38

⁓ okay. Well, last year

I was not here. So I watched the episode as a spectator, also to get inspiration. what I saw is that, all those wishes having to do with the instant payments, VOP, more or less will fulfill somehow rest of Ralf's wishes about SPAA and PSR and all that. Well, he will explain later, but...

Ralf Ohlhausen 8:40

Well, let's just say that in a simple way.

Javier 9:04

I think they have been more disappointing, but the most disappointing ones were your wishes, Starting with the initial ones you mentioned, having a principle-based regulation and fact-based regulation. And that, I think, you miserably failed in those. And I've lost all hope that the institutional fabric will be able

Michael Salmony 9:22

Yes, please.

Javier 9:33

evolve in a different manner. I think especially public administrations will not change. They will for sure not pursue the path of ⁓ fact-based or principle-based regulation because it is not in their interest. So what I see is that those public administrations and other institutions, they pursue their own interests, which may be legitimate. Certainly sometimes they are aligned with public interests. Some others

they are not simply simply that I distrust all those saying that they will save you in your own interest but what I have checked is that what they prescribe is precisely their own interest which it's like a kind of yeah human nature exactly so ⁓ so I have lost faith in that institutional fabric

Michael Salmony 10:20

It's human nature.

Javier 10:31

So my first wish would be that all those drafting new rules get a one year garden leave. So we haven't ever checked whether not having rules is worse than having bad rules. And I think we should give it a try that not having rules for one year, it's just a freeze period, what would happen then? So I think it could be a societal experiment that may also

teach us some good lessons. So that's my first wish to have all those ⁓ drafting new rules to have some vacation, except those in emergency, those rules about emergencies that of course should be enacted. My second wish is related to that, is that I wish we can generate an accountability framework for those institutions that I think we miss also miserably.

Politicians are subject to elections. ⁓ Market entities are subject to the choice of customers. So they may fail. They may be successful. But when coming to public administrations, there is no accountability, not really any accountable instance where you can check whether something was fine or not. And I will give you two examples. First one ⁓ was the retail payments strategy by the Commission.

Apparently in 2020, it was badly needed. It was critical. We needed a strategy. Well, the four year period ended in 2024 and we haven't known anything about it. Whether the goals were achieved or not, whether some things went well, some things went bad. Why don't we have a strategy now? If it was so badly needed five years ago and nobody's caring. So nobody is.

saying, well, this was okay, this was fine, or this was not okay, we should do something differently. So it's forgotten. So no accountability at all. And the same applies to the digital euro and the ECB and the Eurosystem. Nobody is held accountable for whatever will happen and nobody will be accountable for any kind of outcome. my second wish is that we could introduce an accountability framework in our

⁓ in our environment, at least in payments in Europe, which I think we are missing ⁓ very sorry, I would say. So those are my first two. Then I will come to a couple of other wishes, also connected with one of your wishes one year ago, Michael, having to do with industrial policy around payments.

Michael Salmony 13:23

Wonderful, Javier. Those are really innovative thoughts. I think Belgium once didn't have a government for a year or two and they actually did very well. So maybe there is an argument for having a gardening leave and see how that goes. ⁓

Javier 13:32

Yes.

Yeah.

You know, I think, I think we have abandoned the idea of having what Hobbes described as a Leviathan state. Now we are more heading to what Bertrand de Juvenel described as a Minotaur state. The Hobbes one was a static conservative, but this one is very aggressive and dynamic and growing and also always growing. And what I see is that our institutions in Europe and the more I love Europe, the more I don't like how it is functioning.

⁓ They just behave that way. They want to grow in size, in budget, in relevance, but nobody cares about a citizen's goodwill or wishes or interests or needs.

Michael Salmony 14:24

Okay, that's a very critical view. Now, let me offer a few positive things, maybe looking back and a few critical things or where maybe the future is a little uncertain for the future. I mean, looking back, quite honestly, I wasn't a huge fan and still am not of VOP, but it's gone a lot better than I thought it would. In England, it's actually terrible. You know, you have about seven screens before you can actually get through the payment because it checks about...

Javier 14:33

Okay.

Mm-hmm.

Michael Salmony 14:54

Do you really want to make that payment? Is it really the right destination? It's a completely awful process and it costs the banks a lot of money to implement and it obviously doesn't solve any real problem of today, right? Because you're not going to mistype your IBAN. There's a checksum in there, so mistyping an IBAN is not a real problem. And replacing an IBAN through a fraudster, that was the fraud of years ago. That's modern fraud, looks completely different. So, VOP... ⁓

despite the fact that it still doesn't really solve a problem, has actually turned out better than I thought it would. At least the banks that I see in Europe, that I use in Europe, it's only added one step of extra friction and we're through in this maybe slightly pointless exercise. And I hope we'll get round to defeating the modern frauds like APP fraud and things like that in the next iteration. So that's actually quite positive that that VOP wasn't as bad as I thought it might be.

Another light I'm seeing is on the digital euro. And I'm just loving what the rapporteur is saying. You know, because there is not much, I won't say sense coming to some of the proponents, right? It's still a massively interventionistic thing by the state in the private market. There's no real evidence, evidence-based regulation on a real need. All those things have not stopped.

Javier 15:53

Hmm.

Michael Salmony 16:15

But the rapporteur has said, A, we should focus on the offline digital euro, which is exactly right, because that is where the ECB has a mandate. It's a modern version of cash, just in a chip form or in a modern form. And that's absolutely right to do a new modern version of cash so that he's focusing on the offline digital euro. think it's excellent.

And also he's saying the online version, which is the really critical one, because that competes with private industry and all the other problems, that should only come if the private sector doesn't deliver. So if Wero and EPI doesn't succeed, then they have a market failure and then they have a justification. And I think those are excellent points, right? It's going to be critical to see, he's suggesting a market test.

whether the private sector has covered the European market. And I hope he doesn't mean that every single European member state and every bank has to be covered by Wero immediately, because that's setting the bar very high. And we already know that the digital euro isn't going to be satisfying that because they're not even covering the non-Euro countries, which is about seven. So ⁓ that's an interesting one to see, but those are two very positive ones. The VOP wasn't as bad.

Javier 17:32

you

Michael Salmony 17:36

as it might have been, and the digital euro, if the rapporteur gets his way, then that might actually be a really sensible way forward for the digital euro. ⁓ If I can just add one more and then I will maybe come back on the other list. The one that I'm very excited about is the EUID wallet. I think this is a groundbreaking new initiative with some excellent principles. And if we get this right,

Javier 18:00

.

Michael Salmony 18:03

we will actually do something in Europe that I've not seen anywhere else in the world. And if we make this Nordic success a pan-European thing, which makes identity, which is the fundament of everything that we do, if we get that right, and it's also for verifying people and fintechs and things and businesses, attribute-based, it's got a lot of

Javier 18:06

.

Michael Salmony 18:26

things to really like about it. So if we get that right, I think that would be a major step forward also for the payment industry.

I a few more, but I will stop there because I know Ralf is itching to carry on with his list.

Javier 18:37

Thank you.

Ralf Ohlhausen 18:39

As as you've mentioned, digital euro and EUDI Wallet so let me jump to those because I have two other ones which are even closer to like the TPP needs. But nevertheless, let me come to those now. And maybe as well, I fully agree that I also very encouraged by the rappor ⁓

parliament rapporteur Navarrete's report and his views, which I think we share is actually exactly what we have been feeding back to the ECB for the last four years and in one of many occasions. So but he's put it into nice words and a nice report. And yeah, so I fully agree with that. We want offline, we want ⁓ peer to peer settled, we do not want competition to other or private electronic.

payment solutions there. maybe I think one of the one of the also important points you made, which I also fully agree on is that we over the years, we had more and more reasons coming up for having the digital euro that has been mentioned and which is maybe a good side or one side, but essentially it is sort of, as he call it, like a Swiss Army knife, which is trying

Javier 19:54

Okay.

Ralf Ohlhausen 20:00

which would be ⁓ able to address many things a little bit, but none of them good enough. So we have all these big problems and we need the best tool for each problem.

So for some we need a hammer, not a Swiss Army knife, or for some something else we need something more special. And at the end of the day, I think it is just not a good idea to have

Javier 20:17

. Okay.

Ralf Ohlhausen 20:29

public authorities trying to get us competing well in the world with all the other big huge players on payments. on the

wallet, ⁓ yeah, I think it has been moving now a little bit in the right direction. already last year, I was suggesting that while there is a unique opportunity with digital euro,

Javier 20:43

Okay.

Ralf Ohlhausen 20:57

⁓ which I'm not sure will materialize or not. So, but that's a big question mark for that. But to provide a real alternative for us to, especially for all those SCA flows, which are not good or not well implemented by banks, or even if they have it offered a great one for their customers directly, but then they don't do the same through the PSD2 API, which is what we're really suffering from.

from our perspective. So we need a real alternative. so we've put a lot of feedback to the Commission and to these, you know, the ARF, that framework that is now specifying it more precisely, and in particular in relation to the SCA. So I think we ⁓ have provided a lot of feedback. We still have good hopes, but we also see that the large scale pilots are not at all going in that into our direction. They're going into, well, not surprisingly,

Javier 21:34

.

. .

Ralf Ohlhausen 21:56

making it best for banks, but not for open banking. And that's, I think, where we really need

this ⁓ SCA alternative.

Michael Salmony 22:08

Okay.

Javier 22:09

Hm.

Ralf Ohlhausen 22:09

I come back to the other ones later if I get a second, a third

chance.

Michael Salmony 22:12

Well,

we've got a yeah. No, but of course I totally compare it with your, I've written a long paper about this, that there are 40 reasons why CBDC are being introduced around the world. 40. And I think Europe has about five or six. And if you try to solve six things at once, they're probably not going to be solving anything. So.

And the large-scale pilots, I have more of a problem with the size of them. It covers about 13 countries and 40 players, and you're not going to produce anything sensible in that. But I'm still very hopeful on the identity. But sorry, it's not my turn. It's Javier's turn. Sorry.

Javier 22:36

you

Okay.

Well, I guess I will continue with drinking from the sources of last year's episode. And in this occasion, it was about the public policy we need around payments in Europe. You mentioned which has not been delivered for sure, but that has also linked to one of Gijs' wishes, which was that of really creating a true public private partnership. think both are our leaps.

because we have spent years, years in endless discussions on big words. And it's not easy to align what we are talking about. And I will give you some examples. We have been now almost 25 years into this SEPA story. At the very beginning, it was integration. We were asked to do something about integration. It took years to define our...

ground what integration meant. And it meant simply technical standards, common technical standards. So the SEPA schemes were created. The second big hurdle was about competition. There was ⁓ a market failure around competition. It took years to realize that what we needed was to create ⁓ the right framework for payment institutions. And that was a... ⁓

something missing in the regulation. But once payment institutions and E-money institutions were part of the ecosystem, the competition problem somehow disappeared. And we realized that what we had in Europe was a competitiveness issue. And that is still there, competitiveness, but not competition anymore. The third obstacle was about innovation. The industry was criticized because it was not innovative enough.

and we had to devise what innovation was about. And we finally got to the conclusion that it had to do with becoming digital and instant and real time and 24 by 7. But this is in progress, work in progress, I would say. But we really need a very effective dialogue to really understand what we are talking about so that the authorities can ask and the industry can...

bring some solutions or some answers to the questions being posed. Now we are struggling with this sovereignty issue, which still breaks my mind. And I hope that this is my third wish, that we are able to, ⁓ in between the private and the public sectors, to really define what's at stake, what we mean with that. And to me, what we are missing is what I would call better than sovereignty.

SEPA at the POS. We need to have a SEPA solution for the POS, which is far from simply ⁓ labeling it sovereignty. Because for instance, if we are worried about sovereignty in Europe, what about the UK? They should be ⁓ rushing to create something because they are even in worse ⁓ shape in relation to sovereignty in their POS.

So what I think is that we should, or my wish would be that we are able to agree on what the problem is, not yet the solution. The solution will come in 27, 28, but at least during 2026 to define what precisely is needed so that we can solve the sovereignty issue or clearly identify what needs to be implemented by SEPA at the POS. That would be my third wish. And my last one.

which is also connected to this one, because I think we need some additional attributes. I would wish that in 2026, a request to pay and the OCT, the OLO credit transfer take off. And those both elements are needed even for the POS because we need a request to pay to create a pooled instrument at the POS. And we need to go beyond the euro in Europe to have a proper European

cross-European, pan-European solution at POS. And for that we need also to exchange currencies and we should not focus exclusively in Europe. For that we need the OLO credit transfer as well. So my fourth wish would be that in 2026 we see the request to pay, SEPA request to pay and the SEPA OLO credit transfer taking off.

Michael Salmony 27:23

Wonderful, you still have the EPC heart beating in you. One can see it.

Javier 27:27

Yeah,

absolutely, absolutely. think those are still pending tasks to be fulfilled, be fully achieved. Absolutely.

Michael Salmony 27:37

Okay, I only have two more things. One is a very sad thing and the other one is I am hopeful and interested and excited and unsure of where it was going. But the sad thing and it always breaks my heart to say this, I am no longer a believer in open banking in Europe. I think we've screwed this up so badly with the regulation. We've so overregulated it, overcomplicated it, the wrong incentives in all these places that I fear

this is not going anywhere, which is really sad. I've personally actually spent a lot of time on it myself. I've even worked with the regulators initially to help create it. And I'm a huge fan of the topic. think opening up is absolutely the right thing to do. Putting APIs on banks, I think it makes so much sense for consumers, for merchants, for the banks themselves. But we have just so screwed it

I mean, it worked really well initially in Europe. Remember, Europe was the champion in this, right? In Spain and in various other countries. They were doing incredibly well. And then the regulator, not understandably, sort of saw this amazing development, said, wow, this is really powerful and great. But let's put it on a bit more of a sure footing, like only regulated instances can access these APIs and everything.

Let's not have sort of impersonation in there. So lots of noble intentions, but it was so messed up. mean, these hundreds of pages of regulations and six chapters are telling the industry how to do two factor authentication, not having the competition topic in like you were saying, Javier. ⁓ Then I'm afraid also the industry sort of divided itself between SPAA and giroAPI One has the banks, the other one has the fintechs. So that's not moving either. So I am just, I have...

I won't say I've given up on open banking in Europe, but I'm very close to it. The thing that I am sorry to say this, Ralf, I know you've been fighting valiantly for this topic your whole life, and I'm a big fan of the topic and it's wonderful what you've been doing, but I'm just I'm just not seeing it happening. The only way I can see this coming to anything is when it takes off in the UK and it really looks like it. The numbers are really growing and lots of benefits to merchants, to banks, to consumers, to everybody.

Javier 29:32

Mm hmm. Okay.

Michael Salmony 29:53

The US is doing well. And once we see that

this topic is really developing the way it should do, then maybe Europe will throw all this rubbish in the bin and do it properly and incentivize, not just regulate and mandate, but actually give incentives to consumers and merchants and banks to make this happen. And then it'll be a huge success. So sorry about this, but I don't see this going anywhere in PSD3 and PSR and making things only worse, not better.

So I think we're going to have to wait until we see how it's how to do it properly in the UK and the US. So that is my sad topic. The other one which I'm looking forward to with more hope and ⁓ some anticipation is this whole tokenization of money. I find that incredibly interesting. In fact, I'm editing a book on that right now with some colleagues where all these variants of how money is being tokenized with stable coins, deposit tokens.

CBDCs, all these things, I think that is a massive transformation of the industry and of payments. And of course, especially interesting are stable coins. Now, unfortunately, this again is being dominated by the US. It's US denominated stable coins. It's US players like Circle and Tether. So we as Europe have really got to get our act together and quickly on this topic. But because I think this is absolutely fascinating, completely transformative.

and could change the global landscape of payments. So I'm super excited about what's going to be happening in stable coins. So those were my two last things, but I think Ralf was itching to ⁓ a few more.

Javier 31:28

Yeah, yeah, yeah. If I may just add that I'm very sympathetic

to your idea that it is very sad that open banking is not really coming to fruition because I think it's a ⁓ shame that it has been killed by regulation and the public hasn't had a chance to choose. So it does not even reach the market. My ideal would be...

that it's the users, the customers, the ones that finally decide which solutions they want to use. And this hasn't had even the opportunity. So I'm very much in agreement with you.

Ralf Ohlhausen 32:07

Yeah, well, if I may come in on this. So, of course, I share a lot of your sentiments here and I would have loved to turn back the clock and with hindsight, many also the Commission may have come up with different suggestions or maybe less regulation or different regulation, we wouldn't have made some of the mistakes. ⁓

we have. But now as it stands, I, you know, actually, the regulator, or here the Commission is probably the one with the best ideas, what is really what's really ⁓ frustrating is that, well, the parliament isn't even much behind it, and they should be in the interest of competition, everything. whatever they have done, I mean, at least the rapporteur who was in charge there initially,

He's moved the whole thing towards the bank side again. And then of course the council. They have come up with an incredibly difficult and impossible suggestion on how to do things And ever since they have made their suggestions here on PSR, we are just fighting for getting the worst off. We are not talking anymore about improvements. We are talking about how to not make it worse. How to not follow all these

Javier 33:34

You

Ralf Ohlhausen 33:36

proposals coming from this council, especially the Belgium presidency, who has ⁓ done that, that is an absolute catastrophe ⁓ for open banking. So I'm still hopeful that now in the trilogue, at the end, we are coming to the close to the end, but that the Commission will succeed ⁓ in saving ⁓ the situation there. ⁓

Javier 33:53

Okay. ⁓

you

Ralf Ohlhausen 34:07

Yeah, well, we'll see. ⁓ I, so while I share the sentiment and maybe, but I don't share the pessimism, at least not in the long term, because I know, I know that there is no alternative to it. There is no, we have lost five years. And if we are unlucky and the council gets their way, we'll lose another five years. But we will, the idea of the concept will come back and not

just for payments or open banking, also in finance beyond banking and in all the other industries. I'm coming to FIDA in a second, but anyway, so the whole concept of third party providers helping customers to make more out of their data does not just apply to payments or even finance. This is going everywhere and it will succeed everywhere. And even for payments, you know,

Javier 34:38

Okay. Okay.

Michael Salmony 35:00

Absolutely.

Ralf Ohlhausen 35:04

The reason why I'm optimistic in the long term, hopefully midterm,

is that there is no other way to reach every payment account in Europe other than via open banking. We have all these other account to account initiatives and some have whatever a 5 % market share that may grow to 10 to 15 to 20 to whatever, but none of them will ever reach the whole of Europe like what we have with open banking.

We can address every single payment account or bank accounts and all the other non-bank payment accounts. It's the only way to have the coverage. And if you talk about SEPA at POS, know, a merchant wants to enable all their customers walking in, not just those who have an EPI app or not just those who have a Bizum app or not just those who have a card. Because open banking are or reaching the...

Javier 35:35

Okay.

Ralf Ohlhausen 36:01

is essentially the fallback, it's the default.

It's what is behind, it's the only way to reach everyone. Now, digital euro may, if imposed, come in and may also provide access for everyone, but otherwise it is open banking. So I have a long-term optimism on that. well, with SPAA we've failed trying with the stick and regulation and

I don't think that's the way to go anyway. I was hoping that coming with a carrot, we could get the banks in and pay for a good service. Unfortunately, still none so far I wish from last year that dear Santa, please make a bank, join SPAA. Has not come true. He just isn't listened to me or whoever was it. No bank. There's actually one German bank who is sort of at the verge.

but that's one of 5,000. it's not, and I think it's not about, and I think that proves that it's not so much about the payment. You know, we have the giroAPI initiative in Germany, which is sort of similar, and there the banks are there. And the reason for me is not that there is too big a difference in the commercial side, it is because the banks have control. They have 100 % control of that.

Whilst in SPAA they only have 50 % and that's not enough apparently. So for me, therefore, that is also not really the way forward as that I can see. the only third way I hope for now more is more on the standardization side. So with a standard QR code with the...

Javier 37:29

.

Ralf Ohlhausen 37:46

You know, the protocol I mentioned earlier, something that is replacing the old card rails EMVco there and using modern technology with more security and a better way of implementing that at the point of sale. I think that is what I'm hoping for.

Javier 37:59

or

Ralf Ohlhausen 38:01

But now let me finish off and come to FIDA. I've already teased on it because the concept is the same and we should now hopefully learn some lesson on this PSD2.

⁓ and PSR discussions so that with going to FIDA we are not, please, please, Santa, let us not repeat those mistakes. Last year I was saying that ⁓ it should really only focus on the customer access. and I repeat that in my mind, is everyone wants to simplify that law and yeah, it has been killed three times this year and we revived it three times also, I think.

A lot driven by ETPPA trying

Javier 38:47

.

Ralf Ohlhausen 38:48

the sort of a fintech side and countering every bank letter with a counter letter and let's just continue. But it has to come in a way that moves us forward. I am having concerns that if we get it the way the incumbents want it, it'll be worse than not having it. Therefore, we have to

Yes, simplify, but not by reducing the scope, but by reducing the regulation. So in mind, we should just delete articles five and everything that comes behind there. We just need the first four articles of it. That would be a great simplification that gives customer access 24 x 7. And then just don't.

regulate the interaction between the stakeholders, forget all of that, leave it to the customer. It's a customer's data. That's what it's all about. And once a customer has access to their data, they can decide whether they help with it and make more out of it themselves manually or they use AI, is coming big, agentic AI coming big in this space, or maybe hopefully the services offer third party provider to help them make more out of their data.

Javier 39:42

Okay. you

Ralf Ohlhausen 40:02

But it's not for the regulator

to tell the customer on how they should do it. And it's also not to tell the industry how to do it. Please let them stick to the what and do not try and basically stay away from the how for as far as they can.

Michael Salmony 40:25

think we can all agree with that one, absolutely, yeah.

Javier 40:27

Yeah, And I could only complement Ralf's wish with another one, which is whatever has to happen, it happens before we are all bold. So long-term, many times it's too long.

Michael Salmony 40:43

Okay, I think we've used the time quite intensively, so unless anybody has any last-minute wishes to Santa, I would say we close it for now.

So thank you Ralf and Javier for the lovely discussion. I hope everybody listening enjoyed it too. Please comment which wishes you think were good and which you think were missing. always welcome any feedback from any listeners out there. Okay, so I wish you a happy Christmas and I hope you all have as ridiculous jumpers and hats as we do. See you next time.

Javier 41:20

Merry

Ralf Ohlhausen 41:23

Merry Christmas everyone.

Javier 41:23

Christmas and Happy New Year.