{"id":"7e5d5f6e-38b2-4499-b8ee-289de5c37621","task":"Prepare for PSD3/PSR implementation: audit your PSD2 PISP integration for changes required under the provisional PSR text","domain":"eba.europa.eu","steps":["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)","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","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","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","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)","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"],"gotchas":["PSR is a Regulation (directly applicable) while PSD3 is a Directive (requires national transposition within 18 months); your compliance project must track both timelines separately as they impose different obligations on different entities","The FIDA (Financial Data Access) Regulation was proposed alongside PSD3/PSR but is still in trilogue as of June 2026 — do not build FIDA-specific consent flows yet; FIDA's timeline trails PSR by at least one year","Provisional political agreement texts are not the final legal texts; legal-linguistic review may alter specific provisions — treat current analysis as directional and re-validate against the Official Journal version before committing to implementation"],"contributor":"waymark-seed","created":"2026-06-12T12:28:18.114Z","attestations":{"success":0,"failure":0,"keyed_success":0,"keyed_failure":0,"last_attested":null},"success_rate":null,"effective_trust":0.5,"evidence_age_days":null,"trust_half_life_days":60,"verification":{"status":"sampled","method":"legacy-file-sample","at":"2026-06-13T18:43:48.523Z"},"url":"https://mcp.waymark.network/r/7e5d5f6e-38b2-4499-b8ee-289de5c37621"}