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Monday, 11 September 2017

Top Tip: Make Any UK Applications Under #PSD2 From 13 October 2017

The FCA has published several web pages explaining the new authorisation/registration process under the Payment Services Regulations 2017 ("PSRs 2017") and similar process in the existing Electronic Money Regulations 2011 ("EMRs") that are updated by the new PSRs 2017. Basically, firms are "strongly encouraged" by the FCA to make their applications on or after 13 October 2017.

For payment institutions:
"You will be able to submit applications under PSD2 from 13 October 2017, giving you the opportunity to become registered or authorised under the PSRs 2017 from 13 January 2018.
Rather than applying under the PSRs 2009, you are therefore strongly encouraged to make your application under the PSRs 2017, on or after 13 October 2017.
If you decide to apply under the PSRs 2009 and we have not determined your application by 13 January 2018, we will treat your application as being made under the PSRs 2017. This means you will be required to provide more information to us, as required under the new regime [which would likely slow the process down]. If we have determined your application under the PSRs 2009 by 13 January 2018, you will need to submit an application to re-register or become re-authorised under PSD2 and the PSRs 2017, and pay an additional application fee.
Businesses applying for re-authorisation under PSD2 will need to submit a complete application by 13 April 2018 in order to continue operating on or after 13 July 2018.
Businesses applying for re-registration will need to submit a complete application by 13 October 2018 in order to continue operating on or after 13 January 2019."
For e-money institutions:
"You will be able to submit applications under PSD2 and the amended EMRs, from 13 October 2017, giving you the opportunity to be registered or authorised under the new regime from 13 January 2018.
Rather than applying under the current EMRs, you are therefore strongly encouraged to make your application under PSD2 and the amended EMRs, on or after 13 October 2017.
If you decide to apply under the current EMRs and we have not determined your application by 13 January 2018, we will treat your application as being made under the amended EMRs. This means you will be required to provide more information to us, as required under the new regime [which would likely slow the process down]. If we have determined your application under the current EMRs by 13 January 2018, you will need to submit an application to re-register or become re-authorised under PSD2 and the amended EMRs, and pay an additional application fee.
Businesses applying for re-authorisation or re-registration under PSD2 will need to provide all the information we need with an application by 13 April 2018 in order to continue operating on or after 13 July 2018."