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-
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
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