The New EC Green Paper: Missed Opportunities?
13 January 2012
It was interesting to read the European Commission's Green Paper “Towards an integrated European market for card, internet and mobile payments"
published a couple of days ago. My colleague Gareth has already provided some insightful commentary in his blog
below, and I wanted to add a few further points. My first reaction was to applaud the Commission for recognising the increasing convergence of physical and online worlds and deciding to cover in this paper three types of electronic retail payments, namely cards, internet and mobile payments. However, my excitment waned as I continued reading, as the paper is mostly dominated by card-related issues with relatively little attention on internet or mobile payments. Also, in contrast to some very specific issues around cards, such as MIF, cross-border acquiring, specific scheme rules, etc., the questions related to e- and m-payments are rather vague and quite high-level. As a result, we probably shouldn't expect the consultation feedback and responses to be concrete and actionable proposals. The paper envisages that "an integrated EU market for payment services could also produce, as a by-product, administrative data that could be used for the production of harmonised statistics." However, it completely misses the opportunity to recognise the complexities of gathering payment statistics in the converged world, where a card payment might be initiated via a mobile phone, or where an e-wallet might be used to pay for a purchase online, whilst at the same time trigerring a card transaction to fund the wallet. Harmonised payments market by itself will not be sufficient - a common taxonomy and agreement is needed to differentiate between payment instruments and channels, and how various transcations are going to be accounted for. I couldn't help but think that a lot of the questions and phrasings in the paper were a thinly veiled swipe at Visa and MasterCard, two recognised international schemes on which Europe also relies to provide SEPA-compliant international payment instruments. It again raises many of the sensitive issues around MIF, surcharging, co-badging, Honour All Cards rule and others, and the reader is left with a feeling that the Commission would like to see a change in many of today's practices. I could imagine that the schemes must feel rather aggrieved and probably feel that their efforts and investments in maintaining and innovating the payments infrastructure are underappreciated by the authorities. Continuing with the theme of what's missing from the paper, one of the most interesting ommissions to me was the fact that nowhere in the document there is any mention of the need for a third European card scheme. There are probably good reasons for it - we have been conducting some very interesting interviews in the market and will summarise our views in a forthcoming report - keep an eye on it over the next month or so. This is a consultation document and interested parties are encouraged to submit their responses to the Commission by 11 April 2012. The Commission expects that any new proposals would be adopted by Q4/12 or Q1/13, and that "any future legislative or non-legislative proposal will be accompanied by an extensive impact assessment." In other words, it will take some time. And the risk is that the grander the vision, the bigger the likely gap between that vision and the reality, and the longer until the actual changes take place.