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Harmonising Payments
Insights to Progress on the European
Payments Services Directive
Foreword




The Payments Services Directive (PSD) is designed to open up the European payments market to
competition, but, so far, few competitive shots have been fired.

Not just by banks who have a new         payments; contactless cards are
opportunity to compete across            spreading rapidly, leading the way for
borders, by expanding their reach and    mobile payments at point-of-sale; and
by developing new pan-European           new business models on the internet
financial and payments products to       and mobile internet such as in games
acquire new customers, retain existing   and social media are driving demand
ones and create new revenue streams;     for real-time and micropayments
but also by new entrants and non-        solutions.
banks such as telcos who have new
                                         In the meantime, European banks
opportunity to provide alternative
                                         are deep into their PSD programmes
payments services across all 30 EEA
                                         and are using this period to become
(European Economic Area) countries.
                                         compliant with the new legislation
We seem to be in a quiet period, which   – they are analysing the impact
is no doubt being subdued further        of the PSD, and are planning and
by the financial and economic crisis.    implementing changes to their
Nonetheless, there is plenty on the      payments contracts, procedures,
horizon to suggest that the European     processes, products and IT systems.
payments landscape is changing
                                         Accenture conducted this survey to
irreversibly and that competition
                                         get a snapshot of bank readiness for
enabled by regulation such as the
                                         the PSD and for the new competitive
PSD will drive new innovations – for
                                         landscape it enables.
example, mobile banking is on a clear
path towards mass adoption opening
the way for over-the-air mobile




2
Summary
This report presents the results of an Accenture research study
to understand bank preparations for the PSD in the EEA. The
research was facilitated by the EBA (Euro Banking Association)
who distributed the survey to their membership, and was
conducted on-line using facilities provided by Finextra. The
survey objectives are to understand the current state of PSD
readiness and to allow banks to compare their progress against
the market. The research was conducted during May 2009. The
study’s key findings are as follows:

An opportunity to offer pan-                 Banks are getting a clear idea of         PSD programmes are manageable
European Payments                            the PSD impact                            in size
Banks believe that the PSD gives them        All respondents have completed            Respondents indicated their PSD
opportunity to offer services across         their impact assessments, and many        budgets range from less than €1m to
Europe, but few plan to acquire new          have completed planning with              more than €20m, with an average of
customers in doing so. This implies          implementation well underway. We can      €4m. Even allowing for the diversity
their focus is on customer retention.        assume from this that banks have got      in size of responding institutions, this
However, customer retention may              to grips with PSD issues and know what    is a wide range. In the unlikely event
prove to be difficult in corporate           needs to be done to become compliant.     some banks have overestimated or over
banking if corporates rationalise                                                      engineered their PSD programmes, it is
banking relationships for payments           Compliance programmes extend              possible that instead some may have
across Europe.                                                                         underestimated the effort required
                                             across the enterprise
                                                                                       (with implications for their ability to be
                                             The scope of PSD changes appear to be     compliant by 1 November 2009).
Few new products will be
                                             similar in size in retail and corporate
launched on the back of the PSD              banking, with less scope in card
in 2009 and 2010                                                                       Correspondent banking
                                             issuing and acquiring. In response,       arrangements have still to be
PSD efforts are heavily focused on           most respondents have set up holistic,
                                                                                       addressed
achieving compliance with only a few         enterprise-wide programmes to
respondents planning new products            manage the work.                          50% of respondents plan no change
this year and next. It will be interesting                                             to their correspondent banking
to see whether this also applies to the      PSD compliance is as much a               agreements. This does not seem
SEPA Direct Debit, which is also due to                                                viable given the originating bank
                                             business as an IT initiative
be implemented in November 2009.                                                       requirements in the PSD, so it is likely
                                             IT changes account for about 30% of       that many banks have not decided yet
                                             the scope of PSD programmes, with         how they will operate correspondent
New entrants are not perceived               changes to terms and conditions (ts       banking under the PSD.
as a threat                                  & cs) the next biggest component,
Some respondents see new entrants            followed by internal and external
as a serious threat, but most do not.        communication.
Payments Institutions, soon to be
allowed under the PSD, have yet to           Not all banks will be fully
make an impact in the payments               compliant by November 2009
industry.
                                             90% of respondents say they will
                                             be compliant by 1 November 2009,
                                             but work will continue past the
                                             implementation date, particularly to
                                             finish off IT and process changes.




                                                                                                                                  3
Background




The PSD is an EU directive designed to    level playing field for competition. The    business and IT change to implement in
establish a modern and harmonised         key rules which are being standardised      order to be compliant with the PSD.
legal framework for an integrated         concern, inter alia, value dating, fees,
                                                                                      The purpose of this survey is to enable
payments market in the 27 EU              execution times, responsibility/liability
                                                                                      banks to gauge their PSD compliance
countries and in the additional three     and Payments Institutions (new non-
                                                                                      progress against others in the industry.
countries in the EEA. Its objectives      bank, but “bank-lite”, entities which
are to enhance competition, improve       can hold and process payments).
consumer choice and promote greater       Implementation of the PSD by the EEA
efficiency. Currently, each national      countries is a parallel activity to the
government has its own national           implementation of the Single Euro
payments regulations, for example         Payments Area, SEPA, by European
rules on value dating payments, on        banks. SEPA is a Banking industry, self-
direct debit guarantees, on access to     regulated initiative to standardise euro
payments systems. Unsurprisingly,         payment schemes and mechanisms (to
these rules differ across the EEA,        replace national ones), and the PSD
and banks and non-banks wishing to        provides the common legal framework
offer payments have to comply and         in which all payments, including these
configure their operations for each       SEPA payments, can operate.
country where they operate.
                                          The PSD is due to be transposed
This patchwork of regulations is          into the national law of each EEA
inefficient, costly and a barrier to      country by 1 November 2009, with the
pan-European competition. The             exception of Sweden which has delayed
PSD provides one set of rules and         until 2010. The PSD impacts terms
regulations common across the EEA,        and conditions in customer contracts,
thereby breaking down national            products, processes, and IT systems and
barriers and creating a transparent and   banks have a significant amount of




4
The “Calm before the Storm”?
The purpose of the PSD is to harmonise
legal conditions for payments across
the EEA and to promote competition.
We asked respondents for their view
on the opportunities and threats from
this competition:
• What opportunities do you see with
the PSD?
• What is your view of Payments
Institutions and new entrants
encouraged by the PSD?




An opportunity to offer pan-              What opportunities do you see with the PSD?
European Payments                         Number of respondents for a particular category
24 of 29 respondents (82%) see the                        24
PSD as an opportunity to offer pan-
European payments and banking,
but only 4 (14%) believe it is an
opportunity to acquire new corporate
customers, and 2 (7%) believe it is
an opportunity to acquire new retail                                             10

customers.
                                                                                                   5
This implies that we may not see                                                                                            4

many efforts to acquire retail or                                                                                                              2

corporate customers across borders.
                                                  Provide Pan European                                             Acquire new           Acquire new
However, it also implies that corporate           payment and banking
                                                                         Launch new products   Reduce Cost
                                                                                                                   corporate customers   retail customers
                                                  services
customer retention will become a
                                           Source: Accenture research
battle ground – if a corporate has,
say, five banking relationships in five   Exhibit 1: The PSD provides an opportunity to offer Pan-European payments and banking
EEA countries, it could reduce those
to one. If so, only one of the five
banks will retain its customer, the
other four will lose. Provision of new    Only a small number of respondents                                 a catalyst to take out complexity and
pan-European services will not be         see their PSD work as an opportunity                               cost (e.g. through outsourcing) is a
enough – differentiation is required      to reduce cost. Although the work                                  clearly not an objective in most cases.
to win, and banks which are planning      requires a comprehensive overhaul of
new products and services have an         processes, procedures and IT, its use as
advantage.




                                                                                                                                                            5
Few new products will be                     What is your view of Payments Institutions and new entrants
launched on the back of the PSD              encouraged by the PSD?
in 2009 and 2010                             % of respondents within a particular category
10 (34%) of respondents plan to launch
new products; only a small number are            Marginal or no                                                                  63%
                                                 competitive threat
aiming for 1 November 2009, some for
the end of the year (also see Exhibit
8), and the remainder plan to do so in           Opportunity to form
2010 or later. In our experience, PSD            strategic partnerships
                                                                                     18%

programmes and SEPA Direct Debit
projects are often separate streams
                                                 Serious competitive
of work in a bank, so we are unsure              threat
                                                                               11%

whether respondents considered SEPA
DD as a new product in their responses
– however, the SEPA DD is also due for           Opportunity to follow/
                                                 acquire new entrants     8%
implementation in November 09 and
it will be interesting to see whether
the same spread of intentions for            Source: Accenture research


launching new products applies to the        Exhibit 2: Most do not see new entrants as a threat
SEPA DD.

                                             permitted under the PSD will become a
New entrants are not perceived
                                             significant force in European payments.
as a threat                                  However, this view is not universal
Most respondents do not see new              and 11% do see new entrants as a
entrants as a threat. This implies that      serious threat, and 26% see them as
many banks see little evidence at the        an opportunity to partner, acquire or
moment that Payments Institutions            follow.


An industry perspective                      However, transaction banking has                      be bundled with payments – e.g. telcos
                                             proved to be a sustainable and resilient              with location services for m-commerce,
These survey results give the impression     business during the Banking crisis,                   utilities with mass-billing services and
that the PSD’s goal to drive competition     and its growth over the past 5 years,
is a distant one. While the Banking                                                                smart meters, merchants with new
                                             its ability to generate liquidity and its             business models, social media with a
industry may be gearing up to comply         low capital intensity make it an area
with the PSD, only a few banks are                                                                 large customer base to monitise. The
                                             worth competing in; but it is a volume                PSD makes it much easier for non-banks
preparing to compete for new customers       and reach game favouring the large
with new products, and fewer still see                                                             to run their own payments services,
                                             international banks. Therefore, for most
new entrants as a threat. This, perhaps,     banks, competing in payments means                    whether they do so with, or without,
is to be expected given the natural          competing in value added services,                    banks.
inertia in the industry (current payments    and, in our view, value added payments
mechanisms after all work, and have                                                                The increased competition enabled by
                                             services are best developed by bundling or            the PSD may not yet be apparent; but
worked efficiently and effectively for       embedding payments with something else.
many years) and banks often prefer to                                                              there will come a point when it does.
be fast followers rather than leaders in     For example, Paypal bundled with                      We might see signs of banks losing
innovation. Deep cost cutting initiatives    eBay has boosted both businesses                      business as corporates rationalise
in progress across the Banking industry      considerably; payments bundled with                   relationships, or it might be the
do not help, making it difficult to invest   cash management and treasury services                 emergence of a new entrant such as a
in new products and capabilities in the      is boosting revenues in corporate banks;              concerted drive by a telco to provide
current economic climate.                    micropayments embedded into online                    payments services, or it might be
                                             games are creating new revenue streams                mass-adoption of new business models
With the exception of credit cards
                                             for games providers.                                  demanding new payments types.
in retail, and cash management and
trade finance in corporate banking,          New technology (in devices, channels
                                                                                                   The current period is like the calm
historically, payments have not been         and software applications) is a key
                                             factor in value added services, as it                 experienced by mariners before an
a competitive battleground. Banks
have competed on selling products            provides the means to bundle and                      impending storm – while the timing
such as current and savings accounts,        embed payments in other products                      and intensity of the storm are difficult
mortgages, consumer and corporate            and services. This is the battleground                to predict, the PSD is providing the
loans, but they have not on payments         for payments, and non-banks will                      conditions for major and irreversible
– it is not easy to differentiate on cash,   participate as well as banks, for they                change in both the nature of payments
cheque, and electronic payments alone.       have the products and services that can               services and those who provide them.

6
The State of Play (May 2009)
As of May 2009, there is less than         • What is the state of your current
6 months to go before the PSD              PSD implementation planning effort?
implementation on 1 November
                                           • What is the relative proportion of
2009. To achieve compliance by then,
                                           business scope of your PSD programme,
banks have a large volume of effort to
                                           within your institution?
identify the impact on their customers,
products, business processes and IT        • What is the governance structure of
systems and to plan and implement          your programme?
changes to them. At this stage, we
                                           • What is the relative proportion of
would expect most banks to be making
                                           effort within your PSD programme?
good progress, so, to take a snapshot
of how the industry is actually getting
on and tackling the compliance work,
we asked:




Banks are getting a clear idea of          What is the status of your current PSD implementation
the PSD impact                             planning effort?
All respondents have completed             % distribution of responses
impact assessments, and over 70% are
in the detailed planning or execution          Not started              0%
                                                                                                        28% Initial
phases. No one reported that they                                                                       Phases of
                                                                                                        Preparation
have completed their compliance                Impact Assessment                            28%
activities.                                    Completed


The scope of the PSD work is
                                               Detailed Analysisand
determined by the impact assessment,           Planning Completed
                                                                                            28%

and the schedule and approach to                                                                        72% in detailed
                                                                                                        planning and
complete the work is determined                Implementation                                     44%
                                                                                                        execution


by the planning work. From the                 Underway


responses, PSD compliance work
appears to be progressing well across          Completed                0%
                                                                                                        0% finished
Europe, and most banks should have
a good understanding of the impact
                                           Source: Accenture research
of the PSD and of what is required
to achieve compliance. At this stage       Exhibit 3: PSD programmes are progressing well
there should be few unknowns in the
process, although we know through
our PSD client engagements that there
are open issues in interpreting the
PSD for the characteristics intrinsic in
some local payments systems.




                                                                                                                          7
Compliance programmes extend               What is the relative proportion of business scope of your
across the enterprise                      PSD programme, within your institution?
Compliance efforts are focused mainly      average % proportion in each category
on retail and corporate banking in
equal measure, with much less focus                              43%

on card acquiring and issuing (possibly                                                               39%

reflecting the limited number of PSD
articles which directly refer to cards).
With no single dominant or focal
business unit, and with the impact
spread across business units, it is not
surprising that most banks (76% of                                                                                                   10%
                                                                                                                                                                       8%
respondents) have set up holistic,
enterprise wide programmes for
these compliance efforts, rather than
                                                           Retail Banking                     Corporate Banking                 Card Issuing                  Merchant acquiring
separate business unit or geographic
programmes.                                Source: Accenture research

                                           Exhibit 4: The PSD scope is broadly the same in retail and corporate banking


                                           What is the governance structure for your programme?
                                           % distribution of responses

                                                  Centrally Directed,
                                                  enterprise wide                                                                                                 59%
                                                  programme
                                                                                                                                                                                 76%
                                                                                                                                                                                 Integrated
                                                                                                                                                                                 Approach
                                                  Centrally directed
                                                  enterprise wide
                                                  programme with                                       17%
                                                  Country-specific
                                                  projects



                                                  Country-specific                                            21%
                                                  projects

                                                                                                                                                                                 24%
                                                                                                                                                                                 Federal
                                                                                                                                                                                 Approach
                                                  Separate business
                                                  unit projects                  3%




                                           Source: Accenture research



                                           Exhibit 5: Three quarters of PSD programmes are centrally directed

PSD compliance is as much a                 What is the relative proportion of effort within your PSD programme?
business as an IT initiative                 Figure 1: Proportion of high, medium                                             Figure 2: Proportion of programme
Respondents have replied that changes        and low level efforts in Compliance areas                                        budgets for each Compliance area.
to terms and conditions (ts&cs - 19%)        60
and to back office IT (18%) are the                                                                                            Total programme budget: 100%
two biggest components in a PSD              50
programme. Overall, IT change (back                                                                                                             Others , 9%         Terms and Conditions,
                                                                                                                                                                    19%
office and channel) is about 29% of the      40                                                                              Channels IT, 11%

effort, ts&cs, process and procedure
changes 35% and communication                30                                                                              Internal
                                                                                                                             Communications,                                   Back Office
(internal and external) 27%.                                                                                                 12%                                               IT, 18%

                                             20
It is clear that PSD compliance is about                                                                                       Customer
                                                                                                                               Communications, 15%
both business and IT change, and             10
                                                                                                                                                              Policies and
                                                                                                                                                              Processes, 16%

that communication, both internally
with employees, and externally with           0
                                                                                          Back Office Internal
                                                   Terms and    Channels   Processes                                Others
customers is also a large component.               Conditions              and Policies   IT          Communications


                                                    High-> 15% of programme budget              Low- < 5% of the programme budget
                                                    Medium-Between 5-15% of the programme budget
                                           Source: Accenture research

                                           Exhibit 6: IT is the biggest overall component of PSD compliance effort

8
A programme management view                  with relationship managers over
                                             the years. The PSD is proving to be
Accenture works with banks across            a good opportunity to clean up and
Europe on PSD programmes, and in             standardise ts & cs, but it is proving to
our experience the initial impact            be a time consuming one.
assessment is a very diverse exercise
across the enterprise, requiring             The approach to external
participation from a large number of         communications requires careful
stakeholders.                                consideration. It is less time-critical
                                             than other areas, but it is dependent
Typically, the first step is to identify     on the ts &cs activities. Some banks
which products are in scope and              are getting legal advice to send their
which are not in scope, then a central       customers separate communication
team works with the product owners           letters specific to PSD changes,
in the different business units, and         and not include them with regular
with operations and IT owners to             communication such as with bank
identify the different impacts. Such         statements – for high volume retail
is the breadth of change and checking        businesses this is expensive, and can
required, that no-one person is likely       cost €200k – €300k for every 1m
to have sufficient knowledge of the          letters sent out. If banks do not have
business to define all these impacts.        a single view of the customer, then
Consequently, a PSD programme is an          a separate letter for each product a
enterprise-wide programme requiring          customer uses is required, increasing
extensive cooperation and coordination       costs further.
– it is not a single project, nor is it
simply a risk or a legal exercise, but a     The PSD work for many banks has
large number of parallel business, IT        entered the implementation phase.
and operations projects.                     From our experience with other
                                             regulatory compliance programmes
This diversity in the impact assessment      such as MiFID (Markets in Financial
flows through to the planning – as well      Instruments Directive, another
as multiple projects, there is no single     regulatory harmonisation directive
critical path but multiple critical paths,   that became effective on 1 November
and many dependencies between them.          2007), as implementation progresses,
This can be difficult to manage, but it      the focus will soon turn to preparing
does mean that many activities can           for the implementation date itself.
be done in parallel, both in planning        Testing and training will become
and in implementation, and across            important activities for this – testing
businesses and geographies.                  to check the end-to-end process and
The two biggest areas of scope               IT changes work, and training to train
identified in the survey, IT and ts&cs       all impacted employees in a consistent
reflect our experience of PSD client         way and to track training completeness
engagements. Both of these areas are         to show the bank has met its
time critical, whereas communication,        compliance obligations. Customer
internal and external, is less so. IT is     communication is also a critical activity
time critical because there are some         in this phase. Key factors for effective
large IT changes driven by the PSD           communication programmes are the
requirement for immediate availability       clearness of the messages, the level
of funds when received. This is a real-      of detail for different customer types
time processing requirement that is          and the optimum time to send out
particularly difficult to implement          communications (not too early nor too
where payments and accounting                close to 1 November).
systems operate as batch processes
(typically overnight), as is often the
case in many banks.
Ts & cs are time critical due to the
volume of changes required and to
the turnaround time to get corporates
to sign up to them. In our experience,
ts &cs for corporates may not always
exist, or may be decades old and
not reflect additional terms agreed

                                                                                         9
10
The Road to Compliance
With change pervasive across the             • What is your approach to compliance?              We also asked “What is your intent/
enterprise, the goal of compliance by                                                            preference for correspondent banking
                                             • What are your completion
November 2009 is a challenge, even for                                                           in Europe?” to get an idea on how
                                             expectations?
the well prepared and well resourced                                                             banks are addressing correspondent
institutions – bringing together all         • How much are you budgeting for                    banking under the PSD. The PSD places
the business and IT streams of work to       your PSD programmes.                                accountability for the end-to-end
a successful conclusion is a complex                                                             execution time of a payment and for
exercise. It is inevitable that some                                                             fee arrangements on the originating
work will carry on past the 1 November                                                           bank – thus in corresponding banking,
effective date, to tidy up loose ends,                                                           where originating banks typically are
complete non-critical tasks and to set                                                           accountable only for sending payments
up new products and services.                                                                    on the first leg of their journey in
                                                                                                 the network, under the PSD they
To get an idea of how big this challenge
                                                                                                 are accountable for the end-to-end
is, and how confident banks are of
                                                                                                 journey with significant implications
achieving compliance on time, we
                                                                                                 for how correspondent banking
asked:
                                                                                                 operates in the EEA.




Not all banks will be fully                  What is your approach to PSD compliance?
compliant by November 2009                   % of Responses
Although 90% of respondents say
they will be legally compliant by 1              Confidence to achieve
                                                 full compliance by
November, only 72% are confident                 PSD book by
                                                 November 1, 2009
                                                                                                                                  72%

they will be fully compliant by then,
while 21% say they are taking risk               Making risk based
                                                 decisions to become
based decisions on compliance.                   mostly compliant by
                                                                                     21%
                                                 November 1, 2009
Interestingly, the Swedish respondents
(whose regulator has said the PSD will           Would only be
                                                 compliant in certain
be implemented in 2010 after the rest            products/business             7%
                                                 areas by November 1,
of the EEA) expect to be compliant by            2009

November this year.
                                                 No confidence in
                                                 achieving the
We may infer from this that there is             compliance by            0%
                                                 November 1, 2009
high confidence to complete ts&cs
changes by 1 November 2009, but that
confidence is less high for delivering all   Source: Accenture research

the process and IT changes needed to         Exhibit 7: Compliance will not be uniform by 1 November 2009
support these ts&cs by the same date.
Some banks (21%) are exercising              clarification with the local regulator,             their regulator for some leeway on the
judgement to be compliant in critical        but also for complex IT changes which               implementation date for all compliance
but not all areas by 1 November, and         may require compromises in how                      aspects, it is clear that regulatory
work will continue past 1 November           they are implemented (e.g. where real               authorities will need to be realistic that
2009. In our experience, these               time processing is required in batch                not all banks will be fully compliant on
judgements are needed not only for           processing).                                        time. They will need to give guidance
interpretation of the PSD for specific                                                           on what non-compliance is acceptable
local requirements e.g. collection           Although no institution will want to be             and for how long, and to start planning
products in Italy, which may need            the first to request dispensation from              now to develop this guidance.

                                                                                                                                        11
Efforts going on past 1 November           What are your completion expectation?
2009 will be work to complete process
and product changes, and to launch         % distribution of responses in each category
new products. Temporary fixes may be
                                              100%
required e.g. temporarily not charging                          1
                                                                2                  3
                                               90%                                                       6                   6                                  6
correspondent banking fees, until                                                  1
                                               80%
compliant processes and products                                                                         3                                         14
                                               70%
are in place. Additionally it is likely                                                                                      6                                  6
                                               60%
that work to complete and implement
                                               50%                                                                                                  1
corporate opt-out agreements will                               26                25
                                               40%
continue past 1 November 2009. Under                                                                     20                                        9
                                               30%                                                                          17                                  17
the PSD, banks can agree opt-outs
                                               20%
with corporates e.g. on non-mandatory                                                                                                              1
                                               10%
information requirements. While opt-                                                                                                               4
                                                0%
outs can be agreed and documented                         Legally           Customer      All process                All product          New products    All IT changes
in ts &cs before 1 November 2009, the                     Compliant         Communication changes                    changes              launched        completed
                                                                            startted      complete                   complete
IT and process changes to implement
them may follow later. It is also likely          Not planned           By December 31, 2009           Later than 2010           By November 1, 2009     During 2010

that corporate opt-outs may take           Source: Accenture research

time to stabilise once both banks and      Exhibit 8: Legal compliance is achievable without completing all work by 1 November 2009
corporates experience them in practice.




PSD programmes are manageable              How much are you budgeting for your PSD programmes?
in size                                    % of respondents within a particular category
31% of respondents said their PSD                                                             The average PSD programme is budget at around € 4m

budget is less than €1m, and 48%                                                        48%
indicated between €1m and €5m.
Some budgets are much larger, with
21% greater than €5m, with one
estimating the effort at greater than                       31%

€20m. The average of the responses
is €4m.
The wide range of the responses is not
surprising given the spread of banks                                                                              10%
who responded, ranging from small                                                                                                           7%

domestic banks to large global banks.                                                                                                                                4%

However, given 66% of respondents
describe themselves as global or                           < €1m                       € 1-5 m                  € 5-10m                   €10-20m               >€ 20m

multi-country banks, and given the         Source: Accenture research

enterprise-wide nature of the work         Exhibit 9: the average PSD programme is budgeted at around €4m
required, the €4m average budget
seems low.
It is possible that banks are executing    required, but the survey does not                                              the size of programmes reported are
PSD work under “business-as-usual”         provide evidence for this, and with                                            manageable, even for banks which
business unit budgets, and that            72% having completed planning                                                  may have delayed starting work until
mainly centralised budgets for central     (and quantification of the work),                                              this year.
coordination and centralised changes       they should have a good grasp of the
e.g. in IT, have been included in the      budgets they need. The impression
survey results. It is also possible that   from the survey overall is that banks
banks have underestimated the work         have PSD work under control, and

12
Correspondent banking                    With sending banks responsible for end - to - end payments
arrangements have still to be            processes, existing correspondent agreements between banks
addressed                                may not be sufficient under the PSD. What is your preference/
Only about half respondents plan to      intent for correspondent banking in Europe?
renegotiate correspondent banking        % of respondents within a particular category
agreements, and only about a third
of these will negotiate collective           Negotiate new in
agreements (common agreements                dividual agreements
                                             with other banks
                                                                                               28%
                                                                                                                                 48%Changed
with a number of banks), with no                                                                                                 arrangements
                                             Negotiate new
discernable pattern by geography.            collective agreements
                                                                                 17%
                                             with other banks
This may indicate that many banks
have not yet decided how to                  Exit correspondent
                                                                      3%
                                             banking
approach correspondent banking,
as the “do nothing” option does not          Leave existing
                                                                                                                         49%
seem sustainable given the shift of          agreements in place                                                                 52% No
                                                                                                                                 Change
obligations (charges and reach) onto         Not a correspondent
the originating bank. It also suggests       bank                     3%

that banks may be finding it easier to
                                         Exhibit 10: Many banks are planning no change to their correspondent banking arrangements
negotiate new individual agreements      Source: Accenture research

than collective ones.




                                                                                                                                            13
Conclusion
The survey indicates that preparations in       Even with augmented resources, on-       There is a wide range of estimates for
the European Banking industry for PSD           time delivery of the IT solution for a   PSD programme budgets – without
compliance are underway and under               PSD requirement may not always be        knowledge of the underlying detail it
control. Approaches to compliance               feasible. In this case, the business,    is difficult to draw conclusions from
are pragmatic, with enterprise-wide             legal and IT Teams will have to          this. One hypothesis could be that
governance tending to be in favour to           work together to prioritise scope        some banks have underestimated the
deal with the holistic and pervasive            and define operational workarounds       effort required – it would not be the
nature of the changes                           to bridge the gap between the 1          first time that large programmes with
                                                November regulatory deadline and the     significant IT components have been
However, work is being scheduled to                                                      underestimated. Another could be that
                                                full implementation of a particular
continue after the 1 November 2009                                                       budgets for PSD work are decentralised
                                                requirement solution.
implementation date, and although                                                        and buried in business-as–usual
banks are working hard to be compliant          Where delivery of a PSD requirement      activities. Time will tell over the coming
on time, it is unlikely that all banks in all   solution remains feasible but at risk,   months.
30 EEA countries will be fully compliant        Banks will need scenario planning for
                                                                                         At this stage, the focus is more on
by November 2009. In practice, this             the eventuality that compliance is not   compliance than on competitive
means that contractual agreements and           delivered in some areas on 1 November.   positioning – the impact of the PSD
their ts & cs are likely to be in place, but    These plans must be accompanied          on the competitive landscape will be a
not all the IT and operational changes          by a clear date and process by which     story for 2010.
will necessarily be so. Given the fixed         the plan is invoked, and regulators
schedule and pervasive scope of PSD             will need to be prepared for such an
changes, this is unsurprising.                  eventuality.




14
Methodology
The survey was conducted on-line          What best describes your institution?                              Country       Organizations
over a three week period in May 2009.
                                                                                                             Belgium               3
The EBA invited its membership to                                      Domestic Banks
participate, Finextra provided the on-                                 3%                                    Denmark               2

line survey facilities and provided the                                                 Savings Banks        Slovenia
                                                                                                             Slovenia              1

results in anonymous form (institution                                                  3%
                                                                                                             Luxembourg            1
                                          Other Banks
names removed) to Accenture for           28%                                                                Germany               4
analysis and insight. 29 separate
                                                                                                             Ireland               2
institutions responded to the survey.
                                                                                             Multi-Country   Italy                 1
Although there are around 7,000 banks                                                        Banks
in Europe, only around 90 of these are                                                       28%
                                                                                                             Latvia                1

significantly sized, and of these, 19                                                                        Netherlands           2

responded to the survey.                                                                                     Austria               1

                                                                                                             Spain                 1

                                                        Global Banks                                         Sweden                2
                                                        38%
                                                                                                             UK                    8

                                                                                                             Total                29
                                          Source: Accenture research


                                          Exhibit 11: 29 institutions from 13 countries participated




                                                                                                                                           15
About Accenture                               To discuss this survey or to find out more
                                              about how Accenture can help you with
Accenture is a global management              your PSD efforts please contact:
consulting, technology services and           Jeremy Light
outsourcing company. Combining                Global Banking Industry Team
unparalleled experience, comprehensive        jeremy.light@accenture.com
capabilities across all industries and
business functions, and extensive research    Zbigniew Sedzimir
on the world’s most successful companies,     Banking Practice, Germany
Accenture collaborates with clients to        zbigniew.sedzimir@accenture.com
help them become high-performance
businesses and governments. With more
than 181,000 people serving clients in over
120 countries, the company generated net
revenues of US$23.39 billion for the fiscal
year ended Aug. 31, 2008. Its home page is
www.accenture.co.




Copyright © 2009 Accenture.
All rights reserved.

Accenture, its logo, and
High Performance Delivered
are trademarks of Accenture.

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Accenture Payments Survey

  • 1. Harmonising Payments Insights to Progress on the European Payments Services Directive
  • 2. Foreword The Payments Services Directive (PSD) is designed to open up the European payments market to competition, but, so far, few competitive shots have been fired. Not just by banks who have a new payments; contactless cards are opportunity to compete across spreading rapidly, leading the way for borders, by expanding their reach and mobile payments at point-of-sale; and by developing new pan-European new business models on the internet financial and payments products to and mobile internet such as in games acquire new customers, retain existing and social media are driving demand ones and create new revenue streams; for real-time and micropayments but also by new entrants and non- solutions. banks such as telcos who have new In the meantime, European banks opportunity to provide alternative are deep into their PSD programmes payments services across all 30 EEA and are using this period to become (European Economic Area) countries. compliant with the new legislation We seem to be in a quiet period, which – they are analysing the impact is no doubt being subdued further of the PSD, and are planning and by the financial and economic crisis. implementing changes to their Nonetheless, there is plenty on the payments contracts, procedures, horizon to suggest that the European processes, products and IT systems. payments landscape is changing Accenture conducted this survey to irreversibly and that competition get a snapshot of bank readiness for enabled by regulation such as the the PSD and for the new competitive PSD will drive new innovations – for landscape it enables. example, mobile banking is on a clear path towards mass adoption opening the way for over-the-air mobile 2
  • 3. Summary This report presents the results of an Accenture research study to understand bank preparations for the PSD in the EEA. The research was facilitated by the EBA (Euro Banking Association) who distributed the survey to their membership, and was conducted on-line using facilities provided by Finextra. The survey objectives are to understand the current state of PSD readiness and to allow banks to compare their progress against the market. The research was conducted during May 2009. The study’s key findings are as follows: An opportunity to offer pan- Banks are getting a clear idea of PSD programmes are manageable European Payments the PSD impact in size Banks believe that the PSD gives them All respondents have completed Respondents indicated their PSD opportunity to offer services across their impact assessments, and many budgets range from less than €1m to Europe, but few plan to acquire new have completed planning with more than €20m, with an average of customers in doing so. This implies implementation well underway. We can €4m. Even allowing for the diversity their focus is on customer retention. assume from this that banks have got in size of responding institutions, this However, customer retention may to grips with PSD issues and know what is a wide range. In the unlikely event prove to be difficult in corporate needs to be done to become compliant. some banks have overestimated or over banking if corporates rationalise engineered their PSD programmes, it is banking relationships for payments Compliance programmes extend possible that instead some may have across Europe. underestimated the effort required across the enterprise (with implications for their ability to be The scope of PSD changes appear to be compliant by 1 November 2009). Few new products will be similar in size in retail and corporate launched on the back of the PSD banking, with less scope in card in 2009 and 2010 Correspondent banking issuing and acquiring. In response, arrangements have still to be PSD efforts are heavily focused on most respondents have set up holistic, addressed achieving compliance with only a few enterprise-wide programmes to respondents planning new products manage the work. 50% of respondents plan no change this year and next. It will be interesting to their correspondent banking to see whether this also applies to the PSD compliance is as much a agreements. This does not seem SEPA Direct Debit, which is also due to viable given the originating bank business as an IT initiative be implemented in November 2009. requirements in the PSD, so it is likely IT changes account for about 30% of that many banks have not decided yet the scope of PSD programmes, with how they will operate correspondent New entrants are not perceived changes to terms and conditions (ts banking under the PSD. as a threat & cs) the next biggest component, Some respondents see new entrants followed by internal and external as a serious threat, but most do not. communication. Payments Institutions, soon to be allowed under the PSD, have yet to Not all banks will be fully make an impact in the payments compliant by November 2009 industry. 90% of respondents say they will be compliant by 1 November 2009, but work will continue past the implementation date, particularly to finish off IT and process changes. 3
  • 4. Background The PSD is an EU directive designed to level playing field for competition. The business and IT change to implement in establish a modern and harmonised key rules which are being standardised order to be compliant with the PSD. legal framework for an integrated concern, inter alia, value dating, fees, The purpose of this survey is to enable payments market in the 27 EU execution times, responsibility/liability banks to gauge their PSD compliance countries and in the additional three and Payments Institutions (new non- progress against others in the industry. countries in the EEA. Its objectives bank, but “bank-lite”, entities which are to enhance competition, improve can hold and process payments). consumer choice and promote greater Implementation of the PSD by the EEA efficiency. Currently, each national countries is a parallel activity to the government has its own national implementation of the Single Euro payments regulations, for example Payments Area, SEPA, by European rules on value dating payments, on banks. SEPA is a Banking industry, self- direct debit guarantees, on access to regulated initiative to standardise euro payments systems. Unsurprisingly, payment schemes and mechanisms (to these rules differ across the EEA, replace national ones), and the PSD and banks and non-banks wishing to provides the common legal framework offer payments have to comply and in which all payments, including these configure their operations for each SEPA payments, can operate. country where they operate. The PSD is due to be transposed This patchwork of regulations is into the national law of each EEA inefficient, costly and a barrier to country by 1 November 2009, with the pan-European competition. The exception of Sweden which has delayed PSD provides one set of rules and until 2010. The PSD impacts terms regulations common across the EEA, and conditions in customer contracts, thereby breaking down national products, processes, and IT systems and barriers and creating a transparent and banks have a significant amount of 4
  • 5. The “Calm before the Storm”? The purpose of the PSD is to harmonise legal conditions for payments across the EEA and to promote competition. We asked respondents for their view on the opportunities and threats from this competition: • What opportunities do you see with the PSD? • What is your view of Payments Institutions and new entrants encouraged by the PSD? An opportunity to offer pan- What opportunities do you see with the PSD? European Payments Number of respondents for a particular category 24 of 29 respondents (82%) see the 24 PSD as an opportunity to offer pan- European payments and banking, but only 4 (14%) believe it is an opportunity to acquire new corporate customers, and 2 (7%) believe it is an opportunity to acquire new retail 10 customers. 5 This implies that we may not see 4 many efforts to acquire retail or 2 corporate customers across borders. Provide Pan European Acquire new Acquire new However, it also implies that corporate payment and banking Launch new products Reduce Cost corporate customers retail customers services customer retention will become a Source: Accenture research battle ground – if a corporate has, say, five banking relationships in five Exhibit 1: The PSD provides an opportunity to offer Pan-European payments and banking EEA countries, it could reduce those to one. If so, only one of the five banks will retain its customer, the other four will lose. Provision of new Only a small number of respondents a catalyst to take out complexity and pan-European services will not be see their PSD work as an opportunity cost (e.g. through outsourcing) is a enough – differentiation is required to reduce cost. Although the work clearly not an objective in most cases. to win, and banks which are planning requires a comprehensive overhaul of new products and services have an processes, procedures and IT, its use as advantage. 5
  • 6. Few new products will be What is your view of Payments Institutions and new entrants launched on the back of the PSD encouraged by the PSD? in 2009 and 2010 % of respondents within a particular category 10 (34%) of respondents plan to launch new products; only a small number are Marginal or no 63% competitive threat aiming for 1 November 2009, some for the end of the year (also see Exhibit 8), and the remainder plan to do so in Opportunity to form 2010 or later. In our experience, PSD strategic partnerships 18% programmes and SEPA Direct Debit projects are often separate streams Serious competitive of work in a bank, so we are unsure threat 11% whether respondents considered SEPA DD as a new product in their responses – however, the SEPA DD is also due for Opportunity to follow/ acquire new entrants 8% implementation in November 09 and it will be interesting to see whether the same spread of intentions for Source: Accenture research launching new products applies to the Exhibit 2: Most do not see new entrants as a threat SEPA DD. permitted under the PSD will become a New entrants are not perceived significant force in European payments. as a threat However, this view is not universal Most respondents do not see new and 11% do see new entrants as a entrants as a threat. This implies that serious threat, and 26% see them as many banks see little evidence at the an opportunity to partner, acquire or moment that Payments Institutions follow. An industry perspective However, transaction banking has be bundled with payments – e.g. telcos proved to be a sustainable and resilient with location services for m-commerce, These survey results give the impression business during the Banking crisis, utilities with mass-billing services and that the PSD’s goal to drive competition and its growth over the past 5 years, is a distant one. While the Banking smart meters, merchants with new its ability to generate liquidity and its business models, social media with a industry may be gearing up to comply low capital intensity make it an area with the PSD, only a few banks are large customer base to monitise. The worth competing in; but it is a volume PSD makes it much easier for non-banks preparing to compete for new customers and reach game favouring the large with new products, and fewer still see to run their own payments services, international banks. Therefore, for most new entrants as a threat. This, perhaps, banks, competing in payments means whether they do so with, or without, is to be expected given the natural competing in value added services, banks. inertia in the industry (current payments and, in our view, value added payments mechanisms after all work, and have The increased competition enabled by services are best developed by bundling or the PSD may not yet be apparent; but worked efficiently and effectively for embedding payments with something else. many years) and banks often prefer to there will come a point when it does. be fast followers rather than leaders in For example, Paypal bundled with We might see signs of banks losing innovation. Deep cost cutting initiatives eBay has boosted both businesses business as corporates rationalise in progress across the Banking industry considerably; payments bundled with relationships, or it might be the do not help, making it difficult to invest cash management and treasury services emergence of a new entrant such as a in new products and capabilities in the is boosting revenues in corporate banks; concerted drive by a telco to provide current economic climate. micropayments embedded into online payments services, or it might be games are creating new revenue streams mass-adoption of new business models With the exception of credit cards for games providers. demanding new payments types. in retail, and cash management and trade finance in corporate banking, New technology (in devices, channels The current period is like the calm historically, payments have not been and software applications) is a key factor in value added services, as it experienced by mariners before an a competitive battleground. Banks have competed on selling products provides the means to bundle and impending storm – while the timing such as current and savings accounts, embed payments in other products and intensity of the storm are difficult mortgages, consumer and corporate and services. This is the battleground to predict, the PSD is providing the loans, but they have not on payments for payments, and non-banks will conditions for major and irreversible – it is not easy to differentiate on cash, participate as well as banks, for they change in both the nature of payments cheque, and electronic payments alone. have the products and services that can services and those who provide them. 6
  • 7. The State of Play (May 2009) As of May 2009, there is less than • What is the state of your current 6 months to go before the PSD PSD implementation planning effort? implementation on 1 November • What is the relative proportion of 2009. To achieve compliance by then, business scope of your PSD programme, banks have a large volume of effort to within your institution? identify the impact on their customers, products, business processes and IT • What is the governance structure of systems and to plan and implement your programme? changes to them. At this stage, we • What is the relative proportion of would expect most banks to be making effort within your PSD programme? good progress, so, to take a snapshot of how the industry is actually getting on and tackling the compliance work, we asked: Banks are getting a clear idea of What is the status of your current PSD implementation the PSD impact planning effort? All respondents have completed % distribution of responses impact assessments, and over 70% are in the detailed planning or execution Not started 0% 28% Initial phases. No one reported that they Phases of Preparation have completed their compliance Impact Assessment 28% activities. Completed The scope of the PSD work is Detailed Analysisand determined by the impact assessment, Planning Completed 28% and the schedule and approach to 72% in detailed planning and complete the work is determined Implementation 44% execution by the planning work. From the Underway responses, PSD compliance work appears to be progressing well across Completed 0% 0% finished Europe, and most banks should have a good understanding of the impact Source: Accenture research of the PSD and of what is required to achieve compliance. At this stage Exhibit 3: PSD programmes are progressing well there should be few unknowns in the process, although we know through our PSD client engagements that there are open issues in interpreting the PSD for the characteristics intrinsic in some local payments systems. 7
  • 8. Compliance programmes extend What is the relative proportion of business scope of your across the enterprise PSD programme, within your institution? Compliance efforts are focused mainly average % proportion in each category on retail and corporate banking in equal measure, with much less focus 43% on card acquiring and issuing (possibly 39% reflecting the limited number of PSD articles which directly refer to cards). With no single dominant or focal business unit, and with the impact spread across business units, it is not surprising that most banks (76% of 10% 8% respondents) have set up holistic, enterprise wide programmes for these compliance efforts, rather than Retail Banking Corporate Banking Card Issuing Merchant acquiring separate business unit or geographic programmes. Source: Accenture research Exhibit 4: The PSD scope is broadly the same in retail and corporate banking What is the governance structure for your programme? % distribution of responses Centrally Directed, enterprise wide 59% programme 76% Integrated Approach Centrally directed enterprise wide programme with 17% Country-specific projects Country-specific 21% projects 24% Federal Approach Separate business unit projects 3% Source: Accenture research Exhibit 5: Three quarters of PSD programmes are centrally directed PSD compliance is as much a What is the relative proportion of effort within your PSD programme? business as an IT initiative Figure 1: Proportion of high, medium Figure 2: Proportion of programme Respondents have replied that changes and low level efforts in Compliance areas budgets for each Compliance area. to terms and conditions (ts&cs - 19%) 60 and to back office IT (18%) are the Total programme budget: 100% two biggest components in a PSD 50 programme. Overall, IT change (back Others , 9% Terms and Conditions, 19% office and channel) is about 29% of the 40 Channels IT, 11% effort, ts&cs, process and procedure changes 35% and communication 30 Internal Communications, Back Office (internal and external) 27%. 12% IT, 18% 20 It is clear that PSD compliance is about Customer Communications, 15% both business and IT change, and 10 Policies and Processes, 16% that communication, both internally with employees, and externally with 0 Back Office Internal Terms and Channels Processes Others customers is also a large component. Conditions and Policies IT Communications High-> 15% of programme budget Low- < 5% of the programme budget Medium-Between 5-15% of the programme budget Source: Accenture research Exhibit 6: IT is the biggest overall component of PSD compliance effort 8
  • 9. A programme management view with relationship managers over the years. The PSD is proving to be Accenture works with banks across a good opportunity to clean up and Europe on PSD programmes, and in standardise ts & cs, but it is proving to our experience the initial impact be a time consuming one. assessment is a very diverse exercise across the enterprise, requiring The approach to external participation from a large number of communications requires careful stakeholders. consideration. It is less time-critical than other areas, but it is dependent Typically, the first step is to identify on the ts &cs activities. Some banks which products are in scope and are getting legal advice to send their which are not in scope, then a central customers separate communication team works with the product owners letters specific to PSD changes, in the different business units, and and not include them with regular with operations and IT owners to communication such as with bank identify the different impacts. Such statements – for high volume retail is the breadth of change and checking businesses this is expensive, and can required, that no-one person is likely cost €200k – €300k for every 1m to have sufficient knowledge of the letters sent out. If banks do not have business to define all these impacts. a single view of the customer, then Consequently, a PSD programme is an a separate letter for each product a enterprise-wide programme requiring customer uses is required, increasing extensive cooperation and coordination costs further. – it is not a single project, nor is it simply a risk or a legal exercise, but a The PSD work for many banks has large number of parallel business, IT entered the implementation phase. and operations projects. From our experience with other regulatory compliance programmes This diversity in the impact assessment such as MiFID (Markets in Financial flows through to the planning – as well Instruments Directive, another as multiple projects, there is no single regulatory harmonisation directive critical path but multiple critical paths, that became effective on 1 November and many dependencies between them. 2007), as implementation progresses, This can be difficult to manage, but it the focus will soon turn to preparing does mean that many activities can for the implementation date itself. be done in parallel, both in planning Testing and training will become and in implementation, and across important activities for this – testing businesses and geographies. to check the end-to-end process and The two biggest areas of scope IT changes work, and training to train identified in the survey, IT and ts&cs all impacted employees in a consistent reflect our experience of PSD client way and to track training completeness engagements. Both of these areas are to show the bank has met its time critical, whereas communication, compliance obligations. Customer internal and external, is less so. IT is communication is also a critical activity time critical because there are some in this phase. Key factors for effective large IT changes driven by the PSD communication programmes are the requirement for immediate availability clearness of the messages, the level of funds when received. This is a real- of detail for different customer types time processing requirement that is and the optimum time to send out particularly difficult to implement communications (not too early nor too where payments and accounting close to 1 November). systems operate as batch processes (typically overnight), as is often the case in many banks. Ts & cs are time critical due to the volume of changes required and to the turnaround time to get corporates to sign up to them. In our experience, ts &cs for corporates may not always exist, or may be decades old and not reflect additional terms agreed 9
  • 10. 10
  • 11. The Road to Compliance With change pervasive across the • What is your approach to compliance? We also asked “What is your intent/ enterprise, the goal of compliance by preference for correspondent banking • What are your completion November 2009 is a challenge, even for in Europe?” to get an idea on how expectations? the well prepared and well resourced banks are addressing correspondent institutions – bringing together all • How much are you budgeting for banking under the PSD. The PSD places the business and IT streams of work to your PSD programmes. accountability for the end-to-end a successful conclusion is a complex execution time of a payment and for exercise. It is inevitable that some fee arrangements on the originating work will carry on past the 1 November bank – thus in corresponding banking, effective date, to tidy up loose ends, where originating banks typically are complete non-critical tasks and to set accountable only for sending payments up new products and services. on the first leg of their journey in the network, under the PSD they To get an idea of how big this challenge are accountable for the end-to-end is, and how confident banks are of journey with significant implications achieving compliance on time, we for how correspondent banking asked: operates in the EEA. Not all banks will be fully What is your approach to PSD compliance? compliant by November 2009 % of Responses Although 90% of respondents say they will be legally compliant by 1 Confidence to achieve full compliance by November, only 72% are confident PSD book by November 1, 2009 72% they will be fully compliant by then, while 21% say they are taking risk Making risk based decisions to become based decisions on compliance. mostly compliant by 21% November 1, 2009 Interestingly, the Swedish respondents (whose regulator has said the PSD will Would only be compliant in certain be implemented in 2010 after the rest products/business 7% areas by November 1, of the EEA) expect to be compliant by 2009 November this year. No confidence in achieving the We may infer from this that there is compliance by 0% November 1, 2009 high confidence to complete ts&cs changes by 1 November 2009, but that confidence is less high for delivering all Source: Accenture research the process and IT changes needed to Exhibit 7: Compliance will not be uniform by 1 November 2009 support these ts&cs by the same date. Some banks (21%) are exercising clarification with the local regulator, their regulator for some leeway on the judgement to be compliant in critical but also for complex IT changes which implementation date for all compliance but not all areas by 1 November, and may require compromises in how aspects, it is clear that regulatory work will continue past 1 November they are implemented (e.g. where real authorities will need to be realistic that 2009. In our experience, these time processing is required in batch not all banks will be fully compliant on judgements are needed not only for processing). time. They will need to give guidance interpretation of the PSD for specific on what non-compliance is acceptable local requirements e.g. collection Although no institution will want to be and for how long, and to start planning products in Italy, which may need the first to request dispensation from now to develop this guidance. 11
  • 12. Efforts going on past 1 November What are your completion expectation? 2009 will be work to complete process and product changes, and to launch % distribution of responses in each category new products. Temporary fixes may be 100% required e.g. temporarily not charging 1 2 3 90% 6 6 6 correspondent banking fees, until 1 80% compliant processes and products 3 14 70% are in place. Additionally it is likely 6 6 60% that work to complete and implement 50% 1 corporate opt-out agreements will 26 25 40% continue past 1 November 2009. Under 20 9 30% 17 17 the PSD, banks can agree opt-outs 20% with corporates e.g. on non-mandatory 1 10% information requirements. While opt- 4 0% outs can be agreed and documented Legally Customer All process All product New products All IT changes in ts &cs before 1 November 2009, the Compliant Communication changes changes launched completed startted complete complete IT and process changes to implement them may follow later. It is also likely Not planned By December 31, 2009 Later than 2010 By November 1, 2009 During 2010 that corporate opt-outs may take Source: Accenture research time to stabilise once both banks and Exhibit 8: Legal compliance is achievable without completing all work by 1 November 2009 corporates experience them in practice. PSD programmes are manageable How much are you budgeting for your PSD programmes? in size % of respondents within a particular category 31% of respondents said their PSD The average PSD programme is budget at around € 4m budget is less than €1m, and 48% 48% indicated between €1m and €5m. Some budgets are much larger, with 21% greater than €5m, with one estimating the effort at greater than 31% €20m. The average of the responses is €4m. The wide range of the responses is not surprising given the spread of banks 10% who responded, ranging from small 7% domestic banks to large global banks. 4% However, given 66% of respondents describe themselves as global or < €1m € 1-5 m € 5-10m €10-20m >€ 20m multi-country banks, and given the Source: Accenture research enterprise-wide nature of the work Exhibit 9: the average PSD programme is budgeted at around €4m required, the €4m average budget seems low. It is possible that banks are executing required, but the survey does not the size of programmes reported are PSD work under “business-as-usual” provide evidence for this, and with manageable, even for banks which business unit budgets, and that 72% having completed planning may have delayed starting work until mainly centralised budgets for central (and quantification of the work), this year. coordination and centralised changes they should have a good grasp of the e.g. in IT, have been included in the budgets they need. The impression survey results. It is also possible that from the survey overall is that banks banks have underestimated the work have PSD work under control, and 12
  • 13. Correspondent banking With sending banks responsible for end - to - end payments arrangements have still to be processes, existing correspondent agreements between banks addressed may not be sufficient under the PSD. What is your preference/ Only about half respondents plan to intent for correspondent banking in Europe? renegotiate correspondent banking % of respondents within a particular category agreements, and only about a third of these will negotiate collective Negotiate new in agreements (common agreements dividual agreements with other banks 28% 48%Changed with a number of banks), with no arrangements Negotiate new discernable pattern by geography. collective agreements 17% with other banks This may indicate that many banks have not yet decided how to Exit correspondent 3% banking approach correspondent banking, as the “do nothing” option does not Leave existing 49% seem sustainable given the shift of agreements in place 52% No Change obligations (charges and reach) onto Not a correspondent the originating bank. It also suggests bank 3% that banks may be finding it easier to Exhibit 10: Many banks are planning no change to their correspondent banking arrangements negotiate new individual agreements Source: Accenture research than collective ones. 13
  • 14. Conclusion The survey indicates that preparations in Even with augmented resources, on- There is a wide range of estimates for the European Banking industry for PSD time delivery of the IT solution for a PSD programme budgets – without compliance are underway and under PSD requirement may not always be knowledge of the underlying detail it control. Approaches to compliance feasible. In this case, the business, is difficult to draw conclusions from are pragmatic, with enterprise-wide legal and IT Teams will have to this. One hypothesis could be that governance tending to be in favour to work together to prioritise scope some banks have underestimated the deal with the holistic and pervasive and define operational workarounds effort required – it would not be the nature of the changes to bridge the gap between the 1 first time that large programmes with November regulatory deadline and the significant IT components have been However, work is being scheduled to underestimated. Another could be that full implementation of a particular continue after the 1 November 2009 budgets for PSD work are decentralised requirement solution. implementation date, and although and buried in business-as–usual banks are working hard to be compliant Where delivery of a PSD requirement activities. Time will tell over the coming on time, it is unlikely that all banks in all solution remains feasible but at risk, months. 30 EEA countries will be fully compliant Banks will need scenario planning for At this stage, the focus is more on by November 2009. In practice, this the eventuality that compliance is not compliance than on competitive means that contractual agreements and delivered in some areas on 1 November. positioning – the impact of the PSD their ts & cs are likely to be in place, but These plans must be accompanied on the competitive landscape will be a not all the IT and operational changes by a clear date and process by which story for 2010. will necessarily be so. Given the fixed the plan is invoked, and regulators schedule and pervasive scope of PSD will need to be prepared for such an changes, this is unsurprising. eventuality. 14
  • 15. Methodology The survey was conducted on-line What best describes your institution? Country Organizations over a three week period in May 2009. Belgium 3 The EBA invited its membership to Domestic Banks participate, Finextra provided the on- 3% Denmark 2 line survey facilities and provided the Savings Banks Slovenia Slovenia 1 results in anonymous form (institution 3% Luxembourg 1 Other Banks names removed) to Accenture for 28% Germany 4 analysis and insight. 29 separate Ireland 2 institutions responded to the survey. Multi-Country Italy 1 Although there are around 7,000 banks Banks in Europe, only around 90 of these are 28% Latvia 1 significantly sized, and of these, 19 Netherlands 2 responded to the survey. Austria 1 Spain 1 Global Banks Sweden 2 38% UK 8 Total 29 Source: Accenture research Exhibit 11: 29 institutions from 13 countries participated 15
  • 16. About Accenture To discuss this survey or to find out more about how Accenture can help you with Accenture is a global management your PSD efforts please contact: consulting, technology services and Jeremy Light outsourcing company. Combining Global Banking Industry Team unparalleled experience, comprehensive jeremy.light@accenture.com capabilities across all industries and business functions, and extensive research Zbigniew Sedzimir on the world’s most successful companies, Banking Practice, Germany Accenture collaborates with clients to zbigniew.sedzimir@accenture.com help them become high-performance businesses and governments. With more than 181,000 people serving clients in over 120 countries, the company generated net revenues of US$23.39 billion for the fiscal year ended Aug. 31, 2008. Its home page is www.accenture.co. Copyright © 2009 Accenture. All rights reserved. Accenture, its logo, and High Performance Delivered are trademarks of Accenture.