Hervé SITRUK, President, FRANCE PAYMENTS FORUM

The end of a year is a time for taking stock, preparing for the year ahead, and looking ahead to the future. With the European Commission's legislative package at the end of June, notably the draft revision of the Payment Services Directive, and the draft regulations on instant payments, the digital euro, the legal tender of the euro, etc., as well as all the other regulations adopted or in the process of being adopted, such as MiCA, the draft eIDAS2 Directive, and even the Data Act, which have major repercussions on the payments market, the outgoing Commission has delivered a very rich report.

But it's not all there. Despite the Single Payments Area project initiated in 2002, the European payments area remains fragmented, with threats to security, competitiveness, innovation and sovereignty.

On the eve of the European elections, these medium-term issues take center stage, calling for fruitful and hopefully democratic debate. These five key words should mark this debate from the beginning of 2024, and will need to be developed in the following years.

The European Payments Industry has one main objective: to satisfy the payment needs of its customers. This applies to both private individuals and businesses, as well as to public authorities in their relations with citizens. This means offering payment services and solutions that are fluid, user-friendly, secure and resilient, at competitive economic conditions. In this field, Europe can only conclude that it has an industry at the forefront of these various criteria.

But things are changing, and we need to adapt quickly and thoroughly.

The situation is changing as a result of technological developments that offer both the means to better meet the objective, but also bring with them threats. There's no doubt that Cryptography, AI and Quantum technology will revolutionize the entire payments industry within the next ten years. But these technologies also open the way to new forms of fraud and even currency destabilization. They also open up the possibility for so-called global players, with influence over a large part of the world, to set up new private economic and monetary spaces, new global "lordships", which would escape public regulation - which is primarily there to ensure fairness and competitiveness - via complex and Byzantine contractual frameworks that are now beyond the comprehension of ordinary people.

These new technologies also offer certain states the opportunity to extend their monetary supremacy far beyond their domestic economic space, and to impose their economic models, requirements and products and services on the world.

The situation is also changing as a result of the growing, and soon irreversible, imbalance between the economic, banking, industrial and technological players in two major countries - China and the United States - and those in the rest of the world, particularly Europe. Europe remains an economic and regulatory construct in which individual states, some of them very small, preserve their domestic markets, and have yet to see the benefits of having a truly single European payments market with common players able to compete with some chance of success with those outside Europe. This is the result of market fragmentation and the rejection of European solutions in favor of multiple local systems and standards, which need to be constantly brought into contact. Although European regulations and even standardization are advancing effectively in the area of payment, the maintenance of local regulatory or technical specificities is preventing the emergence of less costly pan-European solutions. Europe is also finding it difficult to attract major global leaders. This is a question not only of competition regulation, particularly in terms of service pricing and innovation, but also of corporate financing and investment. Some large European companies are facing market fragmentation and, in response, are undercapitalized and unable to invest for the long term. And fintechs lack a real mechanism for stable financing and bank support.

Finally, the world is changing geostrategically, and the "global village" seems to be living out its last days. This will lead to a multipolar world, with each pole attracting and even integrating more strongly. Europe must choose between becoming a global reference and attraction pole, which would already require greater integration, or becoming part of a new Western pole, necessarily unbalanced and dominated by players from across the Atlantic.

Payments are part of this new situation. And the elections of national representatives to the European Parliament must be the occasion for a debate - democratic, not restricted to experts, and going beyond operational issues - to define the main lines of its development.

In the world of payments, this means combining five key objectives in the future: defragmentation, security, competitiveness, innovation and sovereignty.

Defragmentation : Europe cannot remain a patchwork of national interbank organizations that have to be interconnected, which remains very costly... We need shared pan-European solutions to overcome market fragmentation. We need to set up European interbanking, i.e. cooperation to create common infrastructures and foster the emergence of European solutions and a European culture. These infrastructures must be open to all PSPs and industrial players ready to get involved, and with reinforced requirements both in terms of financial contributions and risk sharing, given the diversity and number of European players in payments. This cooperation can be universal, known as "community", or more restricted to a group of multinational players, known as "collective", as with the EPI initiative. It can cover various areas of the payments business, in geographies that vary according to each player's interests. This is a priority project. Only this approach, which complements single or unified regulations and the standardization work carried out by the EPC, can give us hope of defragmenting the market. But it will take time.

Security: As we've already said, we need to make a major qualitative leap forward, because the threat is already here and growing. But the risk in ten years' time is out of all proportion, and it will take a long time (between 7 and 10 years) to implement responses. After all, it's not just a question of solutions, but also of infrastructure and behavior. The agreement reached in the European Trialogue on the draft European Directive on digital identity is a major step forward, but the payments industry must seize it to avoid having unsuitable solutions imposed on it. It must set up a pan-European digital identity specific to payments, what we call a European Payments Identity, which would not be disconnected either from public identifiers or from the market's KYC rules. The aim is to meet the triple requirement of fluidity, confidentiality and security of transactions. New security methods will gradually be added to this identifier, notably through tokenization and electronic signatures. Cryptopayments, for example, should gradually become a new payment channel, alongside the secure scriptural one, but in a form that can be audited by the market surveillance authorities, to avoid certain recent errors that undermine confidence in these solutions.

Competitiveness: Beyond private initiative, European competitiveness requires a dual approach:

  • First of all, banking and industrial consolidation is essential if a few key players are to emerge, but this requires incentive rules to encourage trans-European cooperation.
  • But we also need a competition policy that authorizes groupings, but also various pricing measures to finance long-term investments, and thus allow returns on investment, and thus encourage investors to intervene in the payments market, which must be profitable. These approaches exist in other fields, and we need to apply them here too.

Innovation: Payments justify a specific innovation policy, due to the diversity of application areas. In payments, Europe has a wealth of talent combining expertise and entrepreneurial spirit, as well as a large number of fintechs. However, two issues need to be tackled head-on: the financing of fintechs, which today is akin to a constant race to the bottom for the managers of these companies, a race that exhausts them and distracts them from developing solutions; and regulatory compliance, which is a major handicap for start-ups.

  • On the financial front, two key mechanisms are missing: firstly, a medium- to long-term revenue advance mechanism for fintechs, which banks could take on, but which requires a credit guarantee system, even if only partial. The research tax credit mechanism cannot be applied to companies with no revenues.... And then a substantial public-sector order on innovation topics of major importance for the future of the payments market. And there is no shortage of such topics.
  • Regulatory compliance is a common requirement to avoid solutions that are far-fetched, risky or even fraudulent. But it would be a good idea to look for mechanisms based on lighter compliance requirements for the first few years, combined with regular audits and close monitoring, or even a compliance assistance scheme.

Sovereignty: Finally, the reaffirmation of European sovereignty in payments, even in its simplified form ("open strategic autonomy"), has yet to bear fruit and is even in danger of being swept away by the incursions of international Big Techs, backed by their capital, their installed base and their armadas of legal experts. Yes to cooperation, no to invasion. European sovereignty is not about having only European economic players, but about having key European players among the players who count in Europe, and if possible beyond, to avoid, if need be, finding ourselves with a ban on the use of international solutions and systems, and the absence of alternative European solutions capable of taking over. And today, in the absence of key European players in various fields, European states are forced to call on certain Big Techs to invest here or there, resulting in unhealthy competition between European national markets. Sovereignty also means supporting European domestic solutions and enabling them to rise to the European level, alone or in partnership, to become one of the players that counts. And for European sovereignty to succeed, we first need to reaffirm the conditions of this sovereignty, then a strong public/private convergence, i.e. mutual trust and reinforced cooperation; we also need to set fair rules for the participation of international players in European markets.

On the first point, in its report entitled "Relocating the payments industry: an imperative for European sovereignty", published on November 16, the Fondation Concorde puts forward concrete, operational recommendations for regaining our sovereignty over payments.

FRANCE PAYMENTS FORUM, which actively contributed to the preparation and communication of this report, shares most of its conclusions.

The report made five key recommendations:

  • The first is an urgent effort to educate and inform on a complex and often misunderstood subject. For Fondation Concorde, the priority is to spread the word that France has a sovereign payment system that is perfectly secure and has proven both its efficiency and resilience. This is a key message of FRANCE PAYMENTS FORUM, and one that has been at the heart of our work for the past 12 years.
  • The second recommendation concerns the adaptation of European regulations. We mentioned this earlier.
  • The third recommendation concerns the digital euro project, with the proposal for a democratic debate on its implementation, and the provision of guarantees regarding confidentiality and data protection. This is a subject that FRANCE PAYMENTS has been covering for the past two years, and our recommendations go well beyond that, to include respect for the current balance of operational roles between PSPs and Central Banks. We'll come back to this later.
  • The fourth recommendation is to promote the development of European banking and industrial players. We've talked about this many times, notably above. Whether it's EPI or the construction of a European card scheme, with those who want it, and the plan to rearm the Groupement des Cartes Bancaires is the first step in this European ambition.
  • The fifth recommendation is to "Protect our strategic assets in the financial services sector, be they our payment systems or our Fintechs". For the Fondation Concorde, "this is no longer an option, but a real imperative if we are to avoid the vassalization of Europe by the great powers", and FRANCE PAYMENTS FORUM can only endorse it.

All this calls for major, long-term investment, and therefore a three-pronged approach involving long-term financing, public procurement and European market integration.

But European sovereignty also depends on strong public/private convergence, and therefore on mutual trust and enhanced cooperation.

The digital euro project was initially conceived as a complementary contribution by the ECB and the Eurosystem to this objective of European sovereignty. However, the technical and financial project proposed by the ECB during the investigation phase lost sight of this objective, and focused solely on the creation of a new retail payment instrument, it seriously undermined trust and cooperation between public and private players.

Following the European Commission's publication of its draft regulation last June, the debate has shifted somewhat, due both to the desire of European co-legislators to regain control of the implementation of the digital euro, and to seek a consensus with all stakeholders, while reaffirming the timeliness and sovereignty stakes of the digital euro, and that of the Central Banks, who want to preserve the "public/private" partnership with the European payments industry.

The current thinking of European co-legislators on the draft European regulation on the digital euro is aimed at bolstering the digital euro project, which they consider to be essential in terms of payment sovereignty, and at regaining control of a project which, in their view, falls within the prerogatives of the States, to refocus the project by extending it to large-value payments, in particular to meet the G20's objectives for the efficiency of international payments, to create the conditions for consensus and a return to confidence with all economic players around retail payments, and to control the cost as central bank shareholders.

On the central bank side, there is a twofold desire: to respect the role of the co-legislators and not to pre-empt anything before the adoption of the final draft regulation, and to preserve the "Public/Private" partnership in payments.

As the Governor of the Banque de France, François VILLEROY de GALAU, said at the CB Forum on November 28, " Payments and money have always been a public/private partnership. This must be clear when it comes to the digital euro ". He added that the digital euro should be seen as " a modern form " of this partnership in payments. And as much as there may be debate about " how " to implement it, we must avoid tearing ourselves apart over " the principle " of the digital euro, so as not to give arguments to the major international competitors.

The Governor opens the game with several proposals:

  • He calls on the banks to seize the opportunity of the democratic debate around the digital euro, to make proposals on "the how", " including the mode of distribution ";
  • He also suggests that the digital euro should not be seen as a new instrument in competition with existing ones, but rather as a means of enriching them and offering them access to all European markets, what he calls the " digital euro inside", "i .e. not only will accounts be opened by banks, but bank applications can also be used, and the digital euro scheme, which will have the merit of harmonizing rules within the euro zone, can also be used for CB-type schemes, .... EPI would obviously be the first potential beneficiary of this harmonization of rules ".

Finally, he calls on all European payment players to build what he calls a " unified ledger ", already proposed in the latest BIS annual report.[1]a " platform for information and exchange of central bank digital money, commercial money, which may also take a tokenized form, based on blockchains, but centered on Europe ", which could compete with the major international platforms for cryptoasset and information exchange. " I think the big challenge for us Europeans (and I think CB is, among others, a key player in this) is to build this European platform. The Eurosystem is ready, together with private players, to look into this."

The democratic debate now underway, which will certainly extend beyond the next European elections, should enable us to return to a project that mobilizes and benefits everyone.

In this way, a consensus could be reached on the principle of issuing a digital euro, and a debate launched on how to implement it. As suggested by the Chairman of Groupement des Cartes Bancaires CB, Jean-Paul MAZOYER, the digital euro should be considered as one of the three "pillars" of the operational implementation of European sovereignty in payments, alongside EPI, and a future European card scheme, of which CB would be one of the key components, which is taken up by the Governor under the term " triangle of sovereignty ".

The strategic payments market, which is as important economically as the aeronautics sector and a net creator of jobs, requires major investment and a strengthened "public/private" partnership. It also requires a political will that needs to be reiterated, updated and, above all, rapidly implemented. The European Commission has partially taken the measure of this with the new legislative package, notably the draft revision of the Payment Services Directive and that on the digital euro. But it is the entire European Payments Strategy that needs to be revised to ensure the effectiveness of a single European market, one that is defragmented, secure, competitive, innovative and sovereign.


[1] Cf. Annual Economic Report 2023 (bis.org) chap 3 p.85 "A new type of financial market infrastructure - a unified ledger - could capture the full benefits of tokenisation by combining central bank money, tokenised deposits and tokenised assets on a programmable platform" .