GREEN PAPER. Towards an integrated European market for card, internet and mobile payments. Contribution by Poste Italiane

Transcription

1 GREEN PAPER Towards an integrated European market for card, internet and mobile payments Contribution by Poste Italiane Green Paper feedback Poste Italiane

2 Contents 4. The need to foster and accelerate market integration Market fragmentation, market access and market entry across borders Multilateral Inter-change Fees (MIFs)... 1 Question n Question n Question n Cross-border acquiring... 2 Question n Question n Co-badging... 3 Question n Question n Separating card schemes and card payment processing... 3 Question n Question n Access to settlement systems... 4 Question n Question n Compliance with the SEPA Cards Framework (SCF)... 5 Question n Information on the availability of funds... 5 Question n Dependence on payment card transactions... 5 Question n Transparent and cost-effective pricing of payment services for consumers, retailers and other businesses Consumer merchant relationship: transparency... 6 Question n Consumer merchant relationship: rebates, surcharging and other steering practices... 6 Question n Merchant payment service provider relationship... 7 Question n Green Paper feedback Poste Italiane

3 4.3. Standardisation... 7 Question n Question n Question n Question n Question n Interoperability between service providers Interoperability in the domain of m-payments Interoperability in the domain of e-payments Interoperability and competition Question n Question n Payments security Question n Question n Question n Question n Strategy implementation/governance Governance of SEPA Question n Governance in the field of cards, m-payments and e-payments Question n Question n General remarks Question n Green Paper feedback Poste Italiane

4 4. THE NEED TO FOSTER AND ACCELERATE MARKET INTEGRATION 4.1. Market fragmentation, market access and market entry across borders Multilateral Inter-change Fees (MIFs) Question n. 1 Under the same card scheme, MIFs can differ from one country to another, and for crossborder payments. Can this create problems in an integrated market? Do you think that differing terms and conditions in the card markets in different Member States reflect objective structural differences in these markets? Do you think that the application of different fees for domestic and cross-border payments could be based on objective reasons? Surveys realized by Central Banks revealed that cost of cash is different for any EU country and that actual structural differences do exist; different levels of MIF among different countries have to be put in relation and must be coherent with different cost of cash in any country. Differences on MIFs are not always mirroring the structural differences, but they are a good approximation to be kept in consideration. It could be useful verifying the application of Tourist Test methodology, proposed by European Commission as first parameter of MIF calculation. Question n. 2 Is there a need to increase legal clarity on interchange fees? If so, how and through which instrument do you think this could be achieved? Probably a regulatory intervention could be needed, as intended to leverage market competition, to eliminate barriers; as an example, regulatory interventions aimed to limit market competition (imposing fixed caps to MSC to be applied by acquirers) must be avoided and not endorsed. Transparency must be found aiming to clarify any cost component of MSC, even on request by merchants (the so called unblending has not to be mandatory, because micro and little merchants could be better supported by a unique MSC). Question n. 3 If you think that action on interchange fees is necessary, which issues should be covered and in which form? For example, lowering MIF levels, providing fee transparency and facilitating Green Paper feedback Poste Italiane Page 1

5 market access? Should three-party schemes be covered? Should a distinction be drawn between consumer and commercial cards? It should be defined a common methodology for the whole SEPA for the definition of interchange fee; in this way electronic payments will grow, especially in those countries where the use of cash is massive. For the Italian market, lowering or clarifying interchange fees is less fundamental than getting more and more convenient the usage of e-money (the level of actual MIFs is not a hurdle for the usage of electronic payments) in spite of alternative ways of paying, such as cash, that represents a huge social cost, not really known by final stakeholders (buyers and merchants). As regarding MIFs applied to different types of cards, these should not reflect the card label (i.e. debit, commercial, etc), but the usage of the cardholder (i.e. the most of commercial cards are used for personal expenditures of the cardholder). That is true in the same way for three party schemes Cross-border acquiring Question n. 4 Are there currently any obstacles to cross-border or central acquiring? If so, what are the reasons? Would substantial benefits arise from facilitating cross-border or central acquiring? We confirm the urgency of completing the standardization process for the acquiring domain, according to the principle of reduction of any business and commercial barrier. On the technical front, Poste Italiane is ready to join the EPAS Consortium (operating in the definition of all the protocols implemented in the SEPA acquiring processes), and is already a member of the Consortium OSCar aimed at implementation and certification of SEPA acquiring standards (EPAS, SEPA-FAST). A further chance in terms of opening to the crossborder acquiring, could be to elimination by Payment Schemes, of the mandatory implementation for proprietary protocols, and/or the certification of just some of them. Indeed we believe that it is up to the Schemes, to define business rules and functional and security requirements, which can then be implemented according to technical standards of free and easy access for all stakeholders. Question n. 5 How could cross-border acquiring be facilitated? If you think that action is necessary, which form should it take and what aspects should it cover? For instance, is mandatory prior authorisation by the payment card scheme for cross-border acquiring justifiable? Should MIFs be calculated on the basis of the retailer s country (at point of sale)? Or, should a cross-border MIF be applicable to cross-border acquiring? Green Paper feedback Poste Italiane Page 2

6 Rules harmonization for cross border acquiring should apply host country domestic MIFs to the merchants entering and distributing goods/services in that market. This is necessary till structural differences between different countries in SEPA will remain Co-badging Question n. 6 What are the potential benefits and/or drawbacks of co-badging? Are there any potential restrictions to co-badging that are particularly problematic? If you can, please quantify the magnitude of the problem. Should restrictions on co-badging by schemes be addressed and, if so, in which form? Through the use of co-badging (co-branding), each Issuer has the ability to diversify the products according to their business and technical requirements, and offering greater flexibility to its customers. Payment Schemes should impose restrictions on licensees Issuer, only in exceptional cases (eg known vulnerabilities on the used platform, brand reputational risk, etc.). Question n. 7 When a co-badged payment instrument is used, who should take the decision on prioritisation of the instrument to be used first? How could this be implemented in practice? As defined in the SEPA Cards Framework, the applications priority should be up to the cardholder free of choice, and in line with the contract agreements with the Issuer. The priority order should still be managed according to the EMV standard, and in second stage, according to the Schemes rules Separating card schemes and card payment processing Question n. 8 Do you think that bundling scheme and processing entities is problematic, and if so why? What is the magnitude of the problem? We believe that it should be granted freedom into a self-regulation market, built on a competitive basis; in this way the process of unbundling would present any problems if the Payment Schemes should allow to third entities to operate the transaction processing, outside of the networks belonging to the Schemes. Green Paper feedback Poste Italiane Page 3

7 In the case of clearing and settlement functions, the Central Banks proposed model could be adopted, allowing all players, of being part to the related activities. Question n. 9 Should any action be taken on this? Are you in favour of legal separation (i.e. operational separation, although ownership would remain with the same holding company) or full ownership unbundling? Separation on legal basis would be a good start! Access to settlement systems Question n. 10 Is non-direct access to clearing and settlement systems problematic for payment institutions and e-money institutions and if so what is the magnitude of the problem? When roles and responsibilities, regarding financial risks about clearing and settlement phases, will be ruled, these operations could be disclosed to other players. In any case equality of conditions must be guaranteed to new entrants, country domestic or SEPA domestic. Question n. 11 Should a common cards-processing framework laying down the rules for SEPA card processing (i.e. authorisation, clearing and settlement) be set up? Should it lay out terms and fees for access to card processing infrastructures under transparent and non-discriminatory criteria? Should it tackle the participation of Payment Institutions and E-money Institutions in designated settlement systems? Should the SFD and/or the PSD be amended accordingly? A SEPA Cards framework should be related to all aspects of card business management. Then, a SEPA clearing and settlement framework could be useful only if aimed to a greater market competition and not as a further regulatory structure. In any case economic conditions and values should not be pre- determined, this could become an hurdle to competition and innovation. Green Paper feedback Poste Italiane Page 4

8 Compliance with the SEPA Cards Framework (SCF) Question n. 12 What is your opinion on the content and market impact (products, prices, terms and conditions) of the SCF? Is the SCF sufficient to drive market integration at EU level? Are there any areas that should be reviewed? Should non-compliant schemes disappear after full SCF implementation, or is there a case for their survival? The SEPA Cards Framework document defines the generic business rules required in terms of compliance for Payment Schemes and Payment Service Providers, and into its scope it can be considered as enough contents. However, we believe that currently is not clear what are the mandatory constraints that any Scheme and PSP shall follow to be considered as SEPA compliant; for sake of clarity, requirements and processes for verification of Scheme compliance, should be more strict and mandatory as in place today. Non-compliant Schemes could disappear (considering the SEPA integration as an irreversible process), but only after a clear and demonstrable non-compliance with a clear technical and legal framework, which now seems not yet well defined Information on the availability of funds Question n. 13 Is there a need to give non-banks access to information on the availability of funds in bank accounts, with the agreement of the customer, and if so what limits would need to be placed on such information? Should action by public authorities be considered, and if so, what aspects should it cover and what form should it take? Such level of openness could be convenient, for particular business needs, only in presence of clear terms and conditions between account holder and provider bank. In any case, money holder has to be kept informed of any risk implied in getting financial information available to financial dealers that are not information holders, giving the possibility of withdraw from the contract to the customers. Furthermore it should be created a safe framework, that will guarantee the customers, giving modular access to the information Dependence on payment card transactions Question n. 14 Given the increasing use of payment cards, do you think that there are companies whose activities depend on their ability to accept payments by card? Please give concrete examples Green Paper feedback Poste Italiane Page 5

9 of companies and/or sectors. If so, is there a need to set objective rules addressing the behaviour of payment service providers and payment card schemes vis-à-vis dependent users? We believe that probably this type of regulatory intervention is necessary for some specific market areas, such as some merchants operating online, or market areas that use card pre authorisations as guarantee of payment (eg: car rental, hotels). Moreover, it s clear in such areas as the use of electronic payment instruments has become a decisive mean of access to services Transparent and cost-effective pricing of payment services for consumers, retailers and other businesses Consumer merchant relationship: transparency Question n. 15 Should merchants inform consumers about the fees they pay for the use of various payment instruments? Should payment service providers be obliged to inform consumers of the Merchant Service Charge (MSC) charged / the MIF income received from customer transactions? Is this information relevant for consumers and does it influence their payment choices? The cost of using payment instruments at merchants could be communicated in transparency when it will be available for all payment means, including cash and other paper based instruments (i.e. cheques). Transparency could become a way of educating in usage payment instruments, without influencing consumer s choice, keeping in mind that for consumer should have no costs in using virtuous payment instruments Consumer merchant relationship: rebates, surcharging and other steering practices Question n. 16 Is there a need to further harmonise rebates, surcharges and other steering practices across the European Union for card, internet and m-payments? If so, in what direction should such harmonisation go? Should, for instance: certain methods (rebates, surcharging, etc.) be encouraged, and if so how? Green Paper feedback Poste Italiane Page 6

10 surcharging be generally authorised, provided that it is limited to the real cost of the payment instrument borne by the merchant? merchants be asked to accept one, widely used, cost-effective electronic payment instrument without surcharge? specific rules apply to micro-payments and, if applicable, to alternative digital currencies? The harmonization must aim to get more profitable the usage of the payment instrument that among others is the most efficient for the most of stakeholders. Identifying preferred ways of accepting, at least, a (new) payment instrument, to be privileged versus cash is the way towards competition and innovation; but the final choice has to be left in customer s hands At the same time, merchants should have the freedom to choose a mark-up to put on top of most inefficient acceptance method, for his business and as a social cost Merchant payment service provider relationship Question n. 17 Could changes in the card scheme and acquirer rules improve the transparency and facilitate cost-effective pricing of payment services? Would such measures be effective on their own or would they require additional flanking measures? Would such changes require additional checks and balances or new measures in the merchant-consumer relations, so that consumer rights are not affected? Should three-party schemes be covered? Should a distinction be drawn between consumer and commercial cards? Are there specific requirements and implications for micro-payments? In general, we think it is difficult to identify a measure that is applicable and manageable in the same way in all national markets Standardisation Question n. 18 Do you agree that the use of common standards for card payments would be beneficial? What are the main gaps, if any? Are there other specific aspects of card payments, other than the three mentioned above (A2I, T2A, certification), which would benefit from more standardisation? Green Paper feedback Poste Italiane Page 7

11 We believe that the activities of the EPASOrg Consortium are well matching in terms of adherence to functional, security, and business requirements, in respect of all its members, that are invited to share in a common factor their own legal and technical needs, and that are joining at the same level each other, in the writing process of technical standards for the T2A domain. Due to its openness to the participants, to its founding principles and accessibility of produced specifications, Poste Italiane is on the way to become EPASOrg Member; it is therefore considered that in the T2A domain, standardization activities are tailored to stakeholders expectations, while other initiatives seem to be a sort of a "black box". - Please note that in the current document is not mentioned is the C2T (card-to-terminal) domain, related to the establishment of common specifications for the card-terminal interface, that now is being run by CIR (Common Implementation Recommendation) Group, in which Poste Italiane is concretely working as well. It should be take into account that CIR activities are essential for achieving a real payment systems interoperability. - Please note that also the OSCar (Open Standards for Cards) Consortium is not being quoted, which on the certification functional side, has the important task of verification and certification of specific implementations in the two standardization groups described above. - For the above mentioned issues, we believe then that both C2T and T2A domains are considered to be interesting and satisfying, in the role and objectives assigned to each of the standardization Initiatives who are in charge of. - Regarding the security requirements standardization activities, Poste Italiane attends to the CAS (Common Approval Schemes) Group, since many years involved in the drafting of common requirements for all SEPA payments markets, and we do believe that, due to the experience and proven achievements from CAS, there is no need to set up any parallel standardization Initiative in the Security domain. - In the scope of certification matters, we observe that the process has been stalled since several years, due to a correct implementation way that is going to be found by the EPC, regarding the accreditation of the so-called "Certification Bodies" and laboratories, for test and verification activities on payment products and processes. We believe that certification processes should come back again as prerogative of Payment Schemes, as reported in the ECB document "6th Progress Report", and that the only responsible for the Type Approval, should be the Payment Schemes; entities such as Banks and Merchant, should return to perform their original roles. - In the A2I domain, we agree with as reported in the Green Paper, and it is believed that, given the versatility of the standard ISO (XML-based) in the banking protocols domain, and also considering its rapid implementation in the SCT and SDD areas, this can be also used in the A2I interbanking domain. What it should been experienced today, is the need for an Acquirer / TMS, that using a ISO20022 "language" in the T2A domain, is being forced to translate all the of financial messages in a ISO8583 "language" in A2I domain. In this regard, it should carefully be considered the activities of the Berlin Group, which has already developed a set of technical specifications for the clearing functions, based on ISO20022 standards. - In summary, and in response to questions: o Yes, from a standardization process (and with clear access criteria for all the participants), the card payments systems would sure have a strong benefit. o Eventual gaps in the standardization process are discernible: Green Paper feedback Poste Italiane Page 8

12 In the criteria marked by lack of transparency and participation in technical activities by the EPC, on issues of governance of the standardization process, regarding all areas to which we discussed above; In the absence of end-dates, needed for the implementation of common standards; In the absence of mandatory constraints required for compliance with the standards, and in the lack of any penalty and liability-shift mechanisms in the case of not met compliance with the standards; In the absence of a common protocol in the A2I domain, based on the ISO20022 financial messages standard; In the use in some cases, of standards (referred to functional, security or certification domains), which are closed, proprietary, and with not easy access for all stakeholders involved in card payments. o In the Green Paper there is not shown the standardization domain C2T, now in the CIR prerogatives. Question n. 19 Are the current governance arrangements sufficient to coordinate, drive and ensure the adoption and implementation of common standards for card payments within a reasonable timeframe? Are all stakeholder groups properly represented? Are there specific ways by which conflict resolution could be improved and consensus finding accelerated? It was not possible to lead the standardization initiatives that already were existing before the establishment of the CSG, and indeed there was an increase of formalism and complexity. It should be underlined the lack of transparency in the access criteria for to the CSG activities, and the low level of communication to stakeholders that are not elected at the CSG plenary, causing loss of interest, frustration and loss of involvement of important stakeholders. For these reasons, it is suggested that functional and technical standardization activities, should be driven by the Eurosystem, by setting up clear deadlines and project milestones. In the interests of full responsibility for all stakheolders, there shall be also be clearly defined responsibilities and rules for common standards implementation (also a constraint for Global Schemes); this activity should not be only lead by the Banking Sector, but by mean a real involvement of all the Sectors representatives. Question n. 20 Should European standardisation bodies, such as the European Committee for Standardisation (Comité européen de normalisation, CEN) or the European Telecommunications Standards Institute (ETSI), play a more active role in standardising card payments? In which area do you see the greatest potential for their involvement and what are the potential deliverables? Are there other new or existing bodies that could facilitate standardisation for card payments? Green Paper feedback Poste Italiane Page 9

13 We re considering that the pure technical activities are already enough representative of the common standardization needs; this does not mean that the joint input of other functional entities could lead to a negative result of ongoing processes, provided that takes into account the already achieved results. Question n. 21 On e- and m-payments, do you see specific areas in which more standardisation would be crucial to support fundamental principles, such as open innovation, portability of applications and interoperability? If so, which? We re considering that technical initiatives that currently on the market are enough to solve the acquiring, security and authorization processes issues, and well balanced according to a self-regulating market. With regard to the standardization process management, please refer to the conclusions of the response number 18. Some effort may be spent in the regulation of non-banking applications on the "chip" media, that if provided in coexistence with previous ones, require a greater level of integration and scalability. Besides, we believe that interoperability between m-payment applications represents a crucial issue to reach a full interoperability between m-payment systems and, in particular, to improve their usage and to guarantee benefits to consumers. At the same time, since the development of applications is still at an emerging phase, it is also important that such interoperability is realized without jeopardizing the legitimate rights of the operators which have (and will) developed new m-payment systems and applications. For instance, a mere portability of m-payment applications (similar to the number portability) would ensure to the recipient operator an unjustified benefit, since its clients would be able to continue to use a m-payment application fully developed by the donating operator, without any form of compensation for the activity of the latter. In essence, a mere portability of m-payment applications would determine a situation in which an operator bears all the efforts and investments for the development of such applications, but the recipient operator can exploits their benefits without any limit. Such situation could clearly constitute a disincentive for the undertakings to develop m- payment systems, since the mobile operators would not be ready to invest for the realization of applications which could be easily used by the clients migrated to competing operators. Question n. 22 Should European standardisation bodies, such as CEN or ETSI, play a more active role in standardising e- or m-payments? In which area do you see the greatest potential for their involvement and what are the potential deliverables? Green Paper feedback Poste Italiane Page 10

14 Please refer to response number 20, we consider that the technical input provided up to now by stakeholders is already enough for the proposed objectives, but we would also propose more action from the Eurosystem in the governance process, and in terms of defining the appropriate regulatory constraints 4.4. Interoperability between service providers Interoperability in the domain of m-payments Interoperability in the domain of e-payments Interoperability and competition Question n. 23 Is there currently any segment in the payment chain (payer, payee, payee s PSP, processor, scheme, payer s PSP) where interoperability gaps are particularly prominent? How should they be addressed? What level of interoperability would be needed to avoid fragmentation of the market? Can minimum requirements for interoperability, in particular of e-payments, be identified? We do not you think that there are particularly evident gaps, but only different business between different sectors, which require regulatory intervention; on the technological front, there are already a clearly defined set of functional requirements (EPC-Book of Requirements), who only needs to be settled definitively (avoiding a Volume lifetime of six months, making it unenforceable), applied and verified by specific Control Bodies, managed by the Eurosystem. We should recall how those constraints should be respected by all actors, including the Global Schemes acting into the SEPA. Question n. 24 How could the current stalemate on interoperability for m-payments and the slow progress on e-payments be resolved? Are the current governance arrangements sufficient to coordinate, drive and ensure interoperability within a reasonable timeframe? Are all stakeholder groups properly represented? Are there specific ways by which conflict resolution could be improved and consensus finding accelerated? The current governance bodies were not able to equally representing all parties involved, either at a decisional level, nor at participation and at communication level. Green Paper feedback Poste Italiane Page 11

15 As already reported in the responses 19 and 23, a mandatory regulatory intervention by the Eurosystem is requested, however, taking into account the principles of business for all stakeholders. The competition in the markets interested by the development of e-payment and m-payment systems could be strongly improved by the setting of common standards, since they allow also the minor undertakings to make their payment systems and devices interoperable with those of the major players. At the same time, a complete interoperability would prevent the main operators from the development and integration on their devices of closed payment systems, which would not be compatible with those of other undertakings. Thus, the identification of minimum common standards for the e-payment and m-payment systems is necessary to ensure an actual competition between all the interested undertakings and to improve a fast development of the usage of these services by the consumers. From the experience of PosteMobile, the main interoperability gap between the payment applications available on the market is represented by the systems of identification and authentication of the user which makes the payment transaction. Such identification is a key feature for the functioning of all the payment applications but, as of today, almost every payment application uses a specific and different authentication system, which is adapted to the specific device. Such situation clearly represents a hurdle for the interoperability between payment applications and, in addition, could lead to a situation in which similar but not compatible payment systems are developed. On the contrary, the identification of a common standard for the user authentication not only would improve the interoperability between the different payment applications, but would also allow all the undertakings to rely on the necessary know-how to develop new systems compatible with the most used applications and devices. In addition, the setting of such standard could represent an opportunity, on the one hand, to improve safer and easier procedures for the user identification and, on the other hand, to avoid that, for every change of device or operator or application, the final user should complete complex identification or authentication procedures which produce "a tough customer experience" and therefore disincentive the usage and the development of such payment services. Green Paper feedback Poste Italiane Page 12

16 4.5. Payments security Question n. 25 Do you think that physical transactions, including those with EMV-compliant cards and proximity m-payments, are sufficiently secure? If not, what are the security gaps and how could they be addressed? We believe that at this time an adequate level of security has been implemented, balanced with a moderate residual risk managed by individual Payment System Providers. Question n. 26 Are additional security requirements (e.g. two-factor authentication or the use of secure payment protocols) required for remote payments (with cards, e-payments or m-payments)? If so, what specific approaches/technologies are most effective? We believe that there are already efficient security mechanisms being in place, that are properly implemented, and applied by the Issuers according to a wise risk management. Question n. 27 Should payment security be underpinned by a regulatory framework, potentially in connection with other digital authentication initiatives? Which categories of market actors should be subject to such a framework? We are considering that the domain is already standardized, even if not in a comprehensive manner for the whole SEPA area. Question n. 28 What are the most appropriate mechanisms to ensure the protection of personal data and compliance with the legal and technical requirements laid down by EU law? In the Italian market, Bank of Italy has already faced steps to issue a guideline document on the implementation and recognition of the so-called "higher security instruments." It would be desirable an expansion to the whole SEPA area, of the principles in security policies, and broad participation in the consultation phase prior to final publication, followed by Bank of Italy. Green Paper feedback Poste Italiane Page 13

17 5. STRATEGY IMPLEMENTATION/GOVERNANCE 5.1. Governance of SEPA Question n. 29 How do you assess the current SEPA governance arrangements at EU level? Can you identify any weaknesses, and if so, do you have any suggestions for improving SEPA governance? What overall balance would you consider appropriate between a regulatory and a selfregulatory approach? Do you agree that European regulators and supervisors should play a more active role in driving the SEPA project forward? As already explained in previous responses, we believe that the SEPA implementation is an irreversible process, and necessarily founded on the principles of market self-regulation. Regarding the standardization process management, please apply the above observations regarding EPC, on organizational transparency and participation in their activities, and access to delivered documentation. Up to date, some important stakeholders do not have access to standardization documents either on a purely informational scope, to the detriment of a total accountability on implementation constraints. It also should be noted that some subjects attending to EPC fora, are representing (also by mean of the same person) more sectors simultaneously (eg banks + Schemes, Schemes + processors) Governance in the field of cards, m-payments and e-payments Question n. 30 How should current governance aspects of standardisation and interoperability be addressed? Is there a need to increase involvement of stakeholders other than banks and if so, how (e.g. public consultation, memorandum of understanding by stakeholders, giving the SEPA Council a role to issue guidance on certain technical standards, etc.)? Should it be left to market participants to drive market integration EU-wide and, in particular, decide whether and under which conditions payment schemes in non-euro currencies should align themselves with existing payment schemes in euro? If not, how could this be addressed? We would confirm that on the technical standardization side, the market should proceed according to a self-regulating mechanisms (in fact, we would underline once again that all the technical specifications produced so far, on both the functional and security domains, are the result of common business requirements coming from all the players participating in different Green Paper feedback Poste Italiane Page 14

18 initiatives), but we stress, as reported in responses 19, 23 and 29, that the governance lead only by the Banking Sector representative, it is unfortunately not be considered satisfactory. The process should be definitively lead and ruled under a clear mandate of the Eurosystem. Question n. 31 Should there be a role for public authorities, and if so what? For instance, could a memorandum of understanding between the European public authorities and the EPC identifying a time-schedule/work plan with specific deliverables ( milestones ) and specific target dates be considered? Please refer to our previous answers, unfortunately the standardization process was not correctly handled, both on the side of respect for the technical and regulatory constraints, and on possible timing constraints; we do also confirms the hope of an Eurosystem intervention, by leaving editorial freedom specifications, with different actors already involved or being in rolling involvement in various standardization Initiatives for the card payment systems domains. The work produced so far is an asset to be safeguarded. Green Paper feedback Poste Italiane Page 15

19 6. GENERAL REMARKS Question n. 32 This paper addresses specific aspects related to the functioning of the payments market for card, e- and m-payments. Do you think any important issues have been omitted or underepresented? In general, the document has covered all aspects related to the processes of the SEPA build; it is believed that some technical standardization initiatives have been neglected (specifically: OSCar, CIR, Berlin Group), and that some were not properly described (specifically true for EPASOrg, CAS Group, OSEC). There is also no mention made to a real and binding SEPA compliance for Payment Schemes, and specifically, under what regulatory obligations they should be mandated (eg management of Certification Authorities and test laboratories ownership). Green Paper feedback Poste Italiane Page 16