PSR card fee transparency: don’t keep merchants in the dark

Merchant Payments Coalition Europe position

The current proposal for Article 31a of the Payment Services Regulation requires fee transparency between card schemes and Payment Service Providers (PSPs), but does not require the same between PSPs and merchants.

Why amendments are needed to ensure equal transparency is available to merchants

• In the absence of a direct contractual relationship with card schemes, merchants lack the ability to influence or negotiate rule and fee changes directly impacting them. The introduction of transparency obligations on card schemes is crucial to ensure acquirers can relay such information to merchants.
• The goal of Article 31a, as per recitals, is to provide transparency for business end users (merchants), in the end benefiting consumers. An important amendment is therefore needed to ensure that the consistent and simple transparency that acquirers will receive from card schemes will be equally available to merchants and will not stop at the acquirer level.
• The current text limits acquirers’ disclosure to IFR (EU 2015/751) provisions (see Art, 31a.1.ii PSR shown below), however, IFR does not mention ‘transparent and consistent disclosure’ of fees and rules, nor the use of a consistent and simple taxonomy of fees.
• Adequate review clauses are needed to ensure flexibility and future-proof the taxonomy by allowing updates to the list of minimum information requirements when necessary.

More about the coalition here.