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The Third Payment Services Directive (PSD3) represents a fundamental modernisation of the EU payments regulatory landscape, introducing harmonised authentication standards, enhanced fraud prevention mechanisms, and a consolidated e-money regime whilst simultaneously addressing the growing intersection between traditional payment services and crypto-assets. Published alongside the Payment Services Regulation, the PSD3 creates a more level playing field for fintechs and non-bank payment service providers, whilst the EBA’s June 2025 opinion on the interplay between PSD3 and MiCA has surfaced material dual authorisation challenges for CASPs dealing in electronic money tokens, with cumulative capital requirements and a critical March 2026 compliance deadline demanding immediate attention. Payment institutions, electronic money institutions, and crypto-asset service providers operating across the EU should treat these developments as an urgent call to action, stress-testing their governance structures, capital buffers, and safeguarding arrangements against the incoming framework now, rather than risk reactive and costly remediation as transitional reliefs expire and supervisory expectations intensify.
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