Periodic update · new data 2026-08-11 · run wpm-2026-08-05Conduct, Safeguarding & Financial Promotions
The proposed successor framework to the EU's second Payment Services Directive comprises two instruments: a revised Payment Services Directive, PSD3, and a new, directly applicable Payment Services Regulation, the PSR. Political agreement on the package was reached in November 2025, the Council approved the text via an I-Item procedure on 22 April 2026, and formal adoption is expected later in 2026, with national implementation across the EU, including in Slovakia, expected around 2027 to 2028. Confidence in this legislative-stage finding is Assessed: sourcing this cycle rests on a single Tier-4 law-firm-insights source, and no direct European Council or European Commission primary text was located to corroborate the precise procedural status independently. The PSD3/PSR package was originally proposed by the European Commission in June 2024, following an extended drafting and negotiation period through Parliament and Council; the November 2025 political agreement and the April 2026 Council I-Item approval represent successive procedural milestones in a multi-year legislative process rather than a sudden development, and firms operating in the EU payments space have had visibility into the package's likely direction since the original 2024 proposal.
The conduct-and-licensing architecture changes proposed under this framework are significant for both bank and non-bank payment-services providers. Electronic money institutions are set to become a sub-category of payment institutions requiring re-authorisation under PSD3, eliminating the separate Electronic Money Directive regime that currently governs EMI licensing; this affects the non-bank payment-institution and e-money-institution population specifically, since banks already operate under a separate prudential licensing track unaffected by the EMD/PI merger. Separately, and affecting both bank and non-bank payment-services providers equally, the Payment Services Regulation's form as a directly applicable EU regulation, rather than a transposed directive, is expected to reduce the conduct-standard fragmentation that currently exists because each Member State transposes PSD2 into its own national law with its own interpretive variations; once the PSR takes effect, conduct standards will apply uniformly across all 27 Member States without a national transposition step. PSD3 itself, as the directive component, will govern authorisations, prudential supervision, and licensing conditions and will require Member State transposition, including by Slovakia; the PSR, as the directly applicable regulation component, will instead govern conduct standards uniformly. This bifurcation, licensing and prudential matters remaining subject to national transposition while conduct matters become directly applicable, is itself a notable structural design choice in the successor framework, since it preserves Member State discretion over authorisation and supervision architecture while removing discretion over conduct-standard content.
For Slovakia specifically, this means that Act No. 429/2009 Coll., the national law that currently transposes PSD2's licensing and conduct requirements, will eventually be superseded once Slovakia nationally implements the PSD3 directive component; the PSR's regulation component will apply directly without requiring a Slovak transposition act at all. Payment institutions and electronic money institutions currently licensed under the Act No. 429/2009 Coll. framework should anticipate a re-authorisation event once the national implementing measures land, though the precise Slovak transposition text and timeline remain two to three years away and were not available this cycle. Both the EMI-reauthorisation finding and the PSR-instrument-form finding carry a HIGH impact classification, reflecting the scale of structural change to the EU payments-conduct rulebook, notwithstanding that the underlying sourcing this cycle sits at Tier-4 confidence.
No Slovakia-specific safeguarding-rule or financial-promotions development was identified this cycle beyond the EU-level PSD3/PSR legislative-stage finding described above; the domain's Slovak-specific signal for this cycle is confined to the anticipated downstream effect of the EU-level legislative process rather than any domestic conduct-rule change already in force.
Outlook
Watch for the PSD3/PSR formal adoption date, expected later in 2026, and for the publication of Slovakia's own national-implementation timeline and transposition text once available, since that text will determine the precise mechanics of the EMI-to-PI re-authorisation event for Slovak-licensed entities. A gap to flag: no direct consilium.europa.eu or ec.europa.eu primary source was located this cycle to independently confirm the Council I-Item procedural status, and closing that gap would materially improve confidence in the current Assessed-tier legislative-stage finding.