Implementation PSD2 postponed
On 22 September 2017 the Dutch Minister of Finance has announced that the implementation of PSD2 in the Netherlands by 13 January 2018 (as required) will not be feasible (link to the letter – Dutch only). The Minister will shortly inform the market on a realistic expected implementation date, which will be in spring 2018.
This seems to allow market parties some breathing time for PSD2 decisions and implementation in the Netherlands. A difficult question is however whether an EU Directive is deemed to apply after its required implementation date, even if the actual implementation in the relevant member state has not yet occurred. We recommend market parties to pay attention to further developments regarding this subject.