Compliance Guide: EU Payment Regulations (2025)
Prepared for Unicorn Currencies clients & partners – June 2025
The EU payment landscape is undergoing its biggest refresh since PSD2. Three headline reforms are shaping compliance obligations in 2025-27:
PSD3 (Third Payment Services Directive)
Council compromise text published 13 June 2025; final directive expected Q4 2025.
Expands SCA scope, tightens AIS/PIS licensing, and boosts fraud-refund rights. National transposition likely mid-2027.
PSR (Payments Services Regulation)
Draft regulation aligned with PSD3; direct EU regulation (no member-state gold-plating).
Creates single rulebook for open-banking APIs; introduces real-time IBAN/name check across EU. Applies 12 months after publication in the EU Journal.
Instant Payments Regulation (IPR)
Adopted 13 Mar 2024; key deadlines: receive instant euro by 9 Jan 2025.
Requires PSPs to offer 24/7 SEPA-Instant at parity pricing with regular credit transfers and verify beneficiary name before execution.
2.1 Strong Customer Authentication (SCA)
PSD3 widens exemptions but introduces mandatory multi-factor for all remote merchant payments over €5 unless risk-scored as low.
Unicorn Currencies' Implementation: Our card stack already uses FIDO2/WebAuthn + behavioural analytics to meet upcoming EBA RTS.
2.2 Safeguarding & Capital
- EMIs will face higher initial capital (€450k → €700k proposed).
- Daily safeguarding reconciliation must settle by T+1
2.3 Fraud & Refunds
- "IBAN/name match" becomes mandatory under PSR and IPR
- PSPs must issue refunds for unauthorised transactions within 24 hours.
Unicorn's payout API will surface a nameMatch boolean before execute.
2.4 Open-Banking APIs
PSD3 merges AIS & PIS into 'Data Access Services'; banks must expose premium data for reasonable fees.
Unicorn Currencies will upgrade to DSP 3.0 endpoints by H2 2026.
Instant Payments Regulation
9 Jan 2025 - Receive instant € (Banks)
Active
9 Oct 2025 - Send + IBAN check (Banks)
Upcoming
9 Apr 2027 - Send + IBAN check (EMIs/PIs)
Future
PSD3 / PSR
13 Jun 2025 - Council compromise
Completed
15 Dec 2025 - Publication in EU Journal (est.)
Expected
15 Dec 2026 - Direct application (PSR)
Future
15 Jun 2027 - Member-state transposition (PSD3)
Future
FCA-authorised EMI
Passported into the EEA via Article 36 regime.
Name-verification API
Live in sandbox Q4 2025.
Real-time fraud scoring
Integrated with EU RCA hot-list.
Safeguarded funds
At Tier-1 European banks plus Bank of England reserves.
GDPR & PII residency
All EU data processed in Frankfurt & Dublin regions.
6.1 Does Unicorn Currencies already support SEPA-Instant?
Yes. All EUR accounts automatically receive SEPA-Instant payments. Outbound instant transfers will be generally available by September 2025, ahead of the regulatory deadline.
6.2 Will my onboarding documents change under PSD3?
No major changes. We may request additional director-level proof-of-address to meet enhanced governance checks, but the online flow remains the same.
6.3 What surcharge will I pay for instant payments?
None. The IPR forbids PSPs from charging more than a standard SEPA Credit Transfer. Unicorn Currencies will apply zero surcharge on EUR instant payouts.
6.4 How do IBAN/name checks work in the API?
Our /payments/quote endpoint returns nameMatch: true/false before execution. If false, the UI prompts sender confirmation to align with PSR Article 55.