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Peer Review Follow-up Report on Authorization under PSD2

The report assesses the extent to which national supervisory authorities in the EEA have followed the recommendations of the 2023 EBA peer review on the authorization of payment institutions and electronic money institutions under PSD2. It looks at authorization processes, supervisory capacity and procedures, the application of the EBA Guidelines, governance and internal control, AML/CFT frameworks, and local substance requirements. The EBA notes clear improvements and greater convergence, but also continuing differences between Member States, leading to varying processing times, varying depth of AML/CFT assessment, and risks of an uneven playing field and regulatory arbitrage.

European Banking Authority December 6, 2025

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