27

November

2025

EU reaches political agreement on Payment Services Directive 3 and Payment Services Regulation

On November 27, 2025, the European Parliament and Council announced they had reached a provisional political agreement on the proposed Payment Services Directive (“PSD3”) and Payment Services Regulation (“PSR”), a legislative package intended to modernize the European Union’s payments framework and replace key elements of Payment Services Directive 2 (“PSD2”). Together, the proposals strengthen fraud protections, increase transparency in fee disclosures for payments and currency conversions, and expand competition by improving access to payment account data for licensed open banking providers.

The proposals would introduce several changes to the EU payments framework. ATM providers would be required to disclose all applicable fees and currency conversion charges before a transaction occurs. Merchants would also be required to ensure that the name appearing on a customer’s bank statement corresponds to the merchant’s trading name to make charges easier to identify. In addition, the legislation would restrict account servicing payment service providers from imposing obstacles that limit licensed third-party access to payment account data. Although a political agreement has been reached, the texts must still undergo technical finalization before formal adoption by the European Parliament and the Council and publication in the Official Journal of the European Union.

Last Updated 11/27/2025.


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Tom Momberg

+17186645458 tom.momberg@dlxlaw.com

Tom advises clients in an array of matters related to blockchain technology, decentralized finance, banking and payments systems, financial products, and financial technology applications. He joined DLx Law as an attorney after working as in-house counsel for a payments and banking software service provider, advising on various legal and regulatory matters, operations, risk, customer due diligence, and corporate best practices.

Tom received his J.D. from George Mason University Law School in Virginia and his B.A. from the University of Wisconsin-Milwaukee. Tom is a former journalist, and, while in law school, he interned for DLx Law and served as a law clerk for several federal institutions in Washington, D.C., including the CFTC, FCC, and House Judiciary Committee. Tom is admitted to practice law in the District of Columbia and the State of Oregon.

Angela Angelovska-Wilson

+12023651448 angela@dlxlaw.com

Angela is an early distributed ledger technology adopter and a leading authority in the evolving global legal and regulatory landscape surrounding distributed ledger technology and smart contracts. Prior to co-founding DLx Law, Angela served as the Chief Legal & Compliance Officer of Digital Asset and was part of the founding team.

Prior to joining Digital Asset, Angela was a partner at Reed Smith where she regularly advised clients on the implementation of new technologies to finance and the complex regulatory schemes involved in the development, creation, marketing, sale and servicing of various financial services and products. Before Reed Smith, Angela spent most of her career in various roles at Latham & Watkins, where she was recognized by The Legal 500 US among the top finance attorneys in the U.S.

Angela has a deep understanding of the Fin-Tech industry and in particular the distributed ledger industry, having been involved in a number of startups in various roles, as an employee, entrepreneur and advisor. In addition to DLx Law, Angela is also co-founder of Sila Inc., an innovative technology company.