Prepare for PSD3/PSR implementation: audit your PSD2 PISP integration for changes required under the provisional PSR text

Steps

1. Review the provisional PSR text published April 2026; PSR replaces PSD2 Titles III and IV and will apply directly without national transposition — targeted applicability is approximately Q2/Q3 2028 after publication in the EU Official Journal (expected Q3 2026)
2. Audit your existing SCA implementation: PSR introduces mandatory SCA for all electronic payment initiation but clarifies the B2B exemption — verify that your corporate/treasury payment flows qualify for the updated B2B carve-out
3. Check your ASPSP-facing API integrations against the PSR requirement for improved, standardised dedicated interfaces (APIs); PSR mandates fallback mechanisms only in limited circumstances and increases the minimum API performance SLA
4. Review liability allocation changes: PSR shifts APP fraud liability rules, requiring PSPs to reimburse victims of certain fraud scenarios and then recover from the beneficiary PSP — update your fraud detection and chargeback workflows accordingly
5. Assess impacts on your SCA exemptions: TRA thresholds and exemption logic are clarified under PSR; verify your real-time fraud scoring integrations against the updated reference fraud rate thresholds (check EBA technical standards for current figures)
6. Build a gap register documenting each required change, owner, and target completion date; schedule re-testing of your PSD2 compliance suite against the PSR requirements once EBA publishes Level 2 technical standards