PSD3 and PSR: New regulatory framework for payment institutions and electronic money from 2026

The year 2026 promises to be a turning point for payment institutions and electronic money operating throughout the European Union, including Poland.

PSD3 and PSR Directives

With the planned entry into force of the PSD3 directive and the new Payment Services Regulation (PSR), the sector is facing significant regulatory changes. The key change is that electronic money institutions will be subject to the full scope of regulations governing the activities of payment institutions.

PSD3 and PSR aim to strengthen the fight against payment fraud and increase the transparency of the payment services market in the European Union. The new framework is intended to improve consumer protection, harmonize the rules for payment service providers, and promote technological innovation.

What are the new obligations and licensing requirements?

The new regulations mean, among other things:

• stricter capital requirements,
• the introduction of broader obligations regarding the protection of customer funds,
• increased ICT resilience,
• and stricter standards for the prevention of financial abuse and fraud.

Institutions that already hold licenses may be required to reapply for authorization or demonstrate compliance with the new standards. Entities that are only planning to apply for a license will have to meet the PSD3 requirements from the outset.

Scope of changes compared to PSD2

PSR and PSD3 are not intended to roll back the achievements of PSD2, but to build on them. They cover issues such as consumer protection, transaction security, authentication standards, and the modernization of payment service provision rules to better reflect current technological and market realities.

New opportunities for non-banking entities

Although the changes mean additional obligations, the new legal order also opens up opportunities for non-bank entities. Increased transparency and uniform requirements can level the playing field with banking institutions and facilitate expansion across the EU.

If you operate in the fintech, payments, or e-money industry, now is the last moment to assess your operational compliance and prepare for new licensing obligations. Don’t wait – contact our team!

PSD3 and PSR Directives

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