COMMISSION STAFF WORKING DOCUMENT EXECUTIVE SUMMARY OF THE IMPACT ASSESSMENT Accompanying the document Proposal for a DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on the comparability of fees related to payment accounts, payment account switching and access to payment accounts with basic features
Date: 2013-05-08
Institutions: European Commission
Subjects: account, bank charges, banking system, consumer protection, credit transfer, electronic money, freedom to provide services, intra-EU payment, single market

EUROPEAN 
COMMISSION 

Brussels, 8.5.2013  
SWD(2013) 165 final 

COMMISSION STAFF WORKING DOCUMENT 

EXECUTIVE SUMMARY OF THE IMPACT ASSESSMENT 

Accompanying the document 

Proposal for a 
DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL 

on the comparability of fees related to payment accounts, payment account switching 
and access to payment accounts with basic features 

{COM(2013) 266 final} 
{SWD(2013) 164 final} 

EN 

   EN 

 
 
 
 
  
 
1. 

INTRODUCTION 

Every citizen of the European Union should have the right of access to basic banking services throughout 
the EU, irrespective of their nationality and / or place of residence since access has become an essential 
condition  for  participation  in  economic  and  social  life.  Such  access  is  not  available  to  all.  Improved 
access to basic banking services would enable every consumer to fully benefit from the internal market, 
by for example, encouraging the free movement of persons and facilitating the purchase of goods cross-
border.  

Furthermore,  unclear  bank  fee  information  makes  it  difficult  for  consumers  to  make  informed  choices 
about which account is best-value for them. Since offers are difficult to compare, EU consumers tend to 
refrain from  switching payment accounts, potentially to an account better suited to their needs. Finally, 
EU consumers who seek to acquire banking services across borders are often hindered by requirements or 
practices in domestic markets that place non-residents at a disadvantage. As a consequence, competition 
in the retail banking sector is hindered. Clearly, these issues and their effects are interrelated, both for the 
individual and the wider economy. This impact assessment aims to address these problems and thereby: 
i. 

Improve the proper functioning of the internal market and avoid the distortion of 
competition in retail banking. The uneven playing field between market actors results 
in reduced competitive rivalry and missed opportunities. Without intervention, there is a 
risk  of  further  fragmentation  in  the  provision  of  payment  accounts,  threatening  long-
term market integration. 
Empower consumers by enabling them to make informed choices. In a competitive 
and efficiently functioning single market with a high level of consumer protection, EU 
citizens  would  have  all  the  tools  necessary,  and  thus  be  empowered  to  search  for  the 
best product for their needs, whether in their own or in another Member State. 
Allow all  European citizens the opportunity to benefit from the single market by 
promoting economic and financial inclusion and through EU-wide access to basic 
banking  services.  Access  to  basic  account  services  will  facilitate  financial  inclusion 
enabling all consumers to participate and benefit from the internal market (including its 
digital  environment).  Improving  access  to  this  key  service  constitutes  an  action  of  the 
European Platform against Poverty and Social Exclusion (a flagship initiative of Europe 
2020), which is designed to combat social exclusion.1   

ii. 

iii. 

The  focus  of  this  impact  assessment  is  on  payment  accounts  held  by  consumers.  Accounts  held  by 
businesses including small or micro enterprises, unless held in a personal capacity, are outside the scope 
of  this  impact  assessment.  This  impact  assessment  does  not  cover  savings  accounts,  which  may  have 
more limited payments functions. 

2. 

CONTEXT 

Previous  efforts  have  been  made  to  address  these  issues.  In  2007,  the  Commission  asked  the  European 
Banking  Industry  Committee  (EBIC)  to  make  it  easier  for  consumers  to  move  their  accounts  from  one 
bank  to  another.  In  response,  EBIC  developed  the  Common  Principles  for  Bank  Account  Switching.2 
Implementation  by  national  banking  associations  was  to  be  completed  by  the  end  of  2009.  However, 

1  The European Platform against Poverty and Social Exclusion: A European framework for social and territorial cohesion 

[COM(2010) 758],  and accompanying document [SEC(2010)1654]. 

2  The Common Principles for Bank Account Switching, 

http://www.eubic.org/Position%20papers/2008.12.01%20Common%20Principles.pdf. 

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research  has  shown  that  their  implementation  is  inadequate3  and  that  the  Common  Principles  fail  to 
properly address all barriers to cross-border mobility. 

In August 2010, the Commission asked EBIC to improve the clarity, comparability, and transparency of 
account fees and ensure that fee information is easily available to consumers. Despite significant efforts 
being made  until the end of 2011 to agree a principles-based  self-regulatory code for payment services 
providers, the initiative failed to produce any results. 
In July 2011, the Commission adopted a Recommendation on access to a basic payment account4 which 
set out principles guaranteeing consumers access to an account throughout the EU. Despite being asked to 
comply with the Recommendation by January 2012, only three Member States5 have a framework in line 
with the Recommendation. Accessing account services is also key to fighting social exclusion.6 
Against  the  background  of  these  self-regulatory  and  regulatory  failures,  the  European  Council  and 
Parliament  have  underlined  the  importance  of  ensuring  that  the  single  market  works  for  all  citizens.  In 
particular,  in  its  Resolution  on  a  single  market  for  Europeans7,  the  European  Parliament  called  on  the 
Commission  to  submit  by  June  2011  a  legislative  proposal  on  guaranteeing  access  to  certain  basic 
banking services and to improve the transparency and comparability of bank charges by the end of 2011. 
The  March  2012  European  Council  welcomed  the  Commission’s  intention  to  propose  a  new  round  of 
measures on payment accounts designed to open up new growth areas in the Single Market. Similarly, a 
recent European Parliament report with recommendations to the Commission on Access to Basic Banking 
Services8 asks the Commission to come forward with a legal proposal in this area by January 2013. 
In addition, the Single Market Act (SMA) II adopted on 3 October 2012 identified a legislative initiative 
on bank accounts in the EU as one of the 12 priority actions to generate real effects on the ground and 
make citizens and businesses confident to use the Single Market to their advantage.9 Its aim is to "give all 
EU  citizens  access  to  a  basic  payment  account,  ensure  bank  account  fees  are  transparent  and 
comparable,  and  make  switching  bank  accounts  easier".10  Furthermore,  the  Commission  announced 
proposals in the area of transparency and comparability of bank fees and bank account switching as part 
of the Commission's Work Programme for 2013.11 

PROBLEM DEFINITION 
Access to a basic account services 

3. 
3.1. 
Research estimates the number of EU citizens with no payment account at between 30 and 68 million.12 
Many  of  those  without  a  payment  account  do  not  need  or  want  one.13  This  may  be  caused  by 
psychological factors in part, as many consumers may simply be scared away by the price, bureaucratic 

3  Consumer Market Study on the consumers’ experiences with bank account switching with reference to the Common 
Principles on Bank Account Switching, GfK, January 2012, BEUC and national studies in UK, Ireland and Austria. 

4   Commission Recommendation 2011/442/EU of 18 July 2011, 2011/442/EU, 18.7.2011. 
5  Belgium, France and Italy. 
6  COM(2010)758 and SEC(2010)1654. 
7  European Parliament Resolution 2010/2278(INI) 
8  European Parliament Resolution 2012/2055(INI). 
9   http://ec.europa.eu/commission_2010-2014/barnier/headlines/news/2012/10/20121003_en.htm 
10  "Single Market Act II - Together for new growth", COM(2012) 573 of 3 October 2012, page 16. 
11  "Commission Work Programme 2013", COM(2012) 629 of 23 October 2012, Annex I, page 5. 
12  Study on the costs and benefits of policy actions in the field of ensuring access to basic account – Final Report (CSES, 
July  2010,  p. 14)  and  calculations  based  on  the  Special  Eurobarometer  on  Retail  Financial  Services  (European 
Commission, February 2012). 

13  Special Eurobarometer on Retail Financial Services, European Commission, February 2012, p. 31. 

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complications  of  accounts,  etc.  It  is  however,  estimated  that  around  half  of  those  who  do  not  have  an 
account want one.14 The reasons why consumers cannot access an account vary. 
Ineffective, inconsistent or non-existent regulatory framework 

Despite Member States being asked to comply with the Recommendation on access to a basic payment 
account15  by  January  2012  and  a  Commission  review  being  announced  for  mid-2012,  as  illustrated  by 
the 
reports  by 
Recommendation’s application sub-optimal and its effects on the marketplace non-existent. 

the  European  Commission  and  Parliament,16  regulatory  failures  have  made 

Limited bank profitability from certain groups of consumers 

Misaligned incentives between the account provider and the consumer lead to rejection of the consumer’s 
application for a payment account. This is particularly true for both vulnerable consumers  who may be 
perceived  by  banks  as  unprofitable  and  for  many  mobile  consumers  on  who  little  information  may  be 
available. 

Limited and more costly access to products and services 

A consumer without an account may find it more difficult and expensive to purchase any other financial 
product as payment accounts often act as a gateway to other financial products and services, e.g. home 
insurance.  Such  consumers  have  limited  opportunities  to  make  use  of  e-commerce  as  the  majority  of 
transactions require a credit card or bank transfer. Other means of payment usually more expensive and 
inconvenient.17 Indeed, a study shows that 22 % of newly banked consumers had shopped by telephone or 
internet since opening their account.18 
Low awareness of availability of basic payment accounts 
In those Member States where basic payment accounts exist, they are often not actively marketed due to 
the misaligned incentives between providers and consumers. 

Discriminatory rules on accessing payment accounts 
The main reason why consumers are rejected for an account is the absence of any regular income; 40 % 
of  consumers  who  were  refused  cited  this  as  the  reason.  Other  common  grounds  for  refusal  are  non-
residence and lack of appropriate documentation. 

Low consumer confidence in the financial system 

Some vulnerable consumers may refrain from opening an account because of the risk that, if in debt, any 
positive balance will be seized.  

Restrictions on the use of basic payment services 

The different characteristics of a basic payment account create a barrier to the internal market, e.g. a basic 
payment  account  can  only  conduct  ‘domestic’  transfers  or  use  ‘domestic’  ATMs.  For  mobile  and 
vulnerable consumers living in border areas or working and living in more than one Member State, this 
represents a significant problem. 

14  Commission services calculations based on Eurostat, Measuring Financial Inclusion, The Global Findex Database, the 
World  Bank,  April 2012,  and  Special  Eurobarometer  on  Retail  Financial  Services,  European  Commission, 
February 2012. 

15  Commission Recommendation 2011/442/EU, 18.7.2011. 
16  European Parliament Resolution 2012/2055(INI)  
17  Banking services and poorer households, Financial Services Taskforce, December 2010. 
18  Nothing  is  free:  A  survey  of  the  social  cost  of  the  main  payment  instruments  in  Hungary,  National  Bank  of  Hungary, 

p. 27. 

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3.2. 

Presentation and ease of comparison of bank fees 

There  is  an  inherent  level  of  complexity  in  the  features  of  payment  accounts  and  in  their  pricing 
structures,  which  leads  to  information  asymmetries  and  hinders  consumer  choice  and  competition 
amongst providers. 

A wide range of services and fees 

Payment  accounts  cover  a  wide  range  of  services  and  charging  structures  may  be  complex.  Fee 
complexity impacts upon a consumer’s ability to understand what fees represent. Yet understanding fees 
is a prerequisite to comparing different offers. 

Pricing models 

Some  pricing  models  appear  to  have  simpler  charging  structures  (e.g.  package  based,  indirect  revenue-
based)  than  others  (transaction  based,  account-based).  Although  national  markets  often  exhibit  a 
prevalence  of  one  pricing  model  over  others,  more  than  one  model  is  in  use  in  a  number  of  Member 
States. While this diversity provides a broader choice of products and is not a negative feature, it further 
adds to the complexity of choosing an appropriate product. 

Simplicity and transparency of fees 

The use of differing terminology referring to the same type of services may make it difficult to compare 
bank offers. Research19 found that while two thirds of financial institutions provided fee information on 
their websites, 69 % of banks did not provide clear information and further contact was needed to obtain 
clarifications on the fees as disclosed. 

Price dispersion in payment accounts within and across Member States 

Wide price variations have been observed for payment accounts, calling into question the degree of price 
competition in the market. Price variations also feed the perception that payment accounts are not fairly 
priced, denting consumer confidence and trust in the sector. 

Customer price discrimination 
Price discrimination occurs between different customers so that their cost for a product with comparable 
features  would  not  be  the  same.  Further,  introductory  pricing  offers  adds  another  barrier  to  clear  and 
comparable  bank  offers  and  makes  it  more  difficult  for  a  consumer  to  understand  longer-term  costs 
associated with holding an account. 

Ineffective, inconsistent or non-existent regulatory framework 

The  current  regulatory  framework  varies  widely  across  Member  States,  in  terms  of  scope  and  depth. 
While credit institutions are required to provide consumers with contractual terms and conditions when 
opening  an  account,  many  Member  States  do  not  mandate  specific  presentation  requirements. 
Requirements  on  ex-post  information  also  differ  widely.  Uncoordinated  national  actions  results  in  an 
uneven playing field within the internal market, meaning that EU citizens do not enjoy the same level of 
consumer protection. 

3.3. 

Payment account switching 

Potential  and  actual  customer  mobility  creates  competition  between  providers  and  encourages  them  to 
offer  better  quality  and  cheaper  products.  However,  research20  has  shown  that  this  is  not  the  case  for 
payment accounts. The factors currently limiting switching are as follows: 

19  Preparing  the  monitoring  of  the  impact  of  the  Single  European  Payments  Area  (SEPA)  on  consumers,  Van  Dijk 

Management Consultants, 2008. 

20  The Consumer Market Study on the consumers’ experiences with bank account switching with reference to the Common 
Principles  on  Bank  Account  Switching,  GfK,  January 2012  and  studies  by  BEUC  and  at  national  level  (UK,  Ireland, 
Austria). 

5 

 
 
                                                            
Inadequate information 
The Common Principles21 require the provision of information on the switching process, but this does not 
happen. Research22 found that whilst in 86 % of the cases, information was provided either in a branch, 
online  or  by  telephone,  the  level  of  information  provided  varied  widely.  In  a  third  of  enquiries,  no 
information on switching was available on the bank’s website. In 45 % of cases, no detailed information 
on the process was provided and in 80 % of cases, no explanatory documentation was given. 

Complexity of switching process 

Difficulties transferring standing orders and direct debits represent one of the major barriers to account 
mobility; research23 found that in two thirds of cases, consumers were told that the bank could not assist 
them with the transfer of standing orders. Account switching costs consumers time and effort. In 2009, 
around 21 million consumers did not switch accounts because the cost and effort involved was too large.24 
It  is  often  unclear  how  long  the  process  will  take  and  what  will  happen  to  direct  debits/credits  in  the 
‘transitional  period’.  Research  also  shows  that  the  deadlines  set  in  the  Common  Principles  are  not 
respected.25 
Direct financial costs 

Consumers  switching  current  accounts  bear  direct  financial  costs  such  as  the  cost  of  maintaining  two 
accounts, for the duration of the switching process. Other direct costs that may be incurred are an account 
balance transfer fee and correspondence costs. 

Psychological factors 

Consumer perceptions can deter switching. In the Netherlands, despite there being an account redirection 
system since 2004, switching rates are low. One reason is there remains a perception that the process is 
difficult, despite the fact that those who have switched using the redirection service found it easy.26 
Restricted cross-border switching 

The self-regulatory Common Principles do not apply to cross-border switching, which continues to be 
characterised by separate opening and closing of account procedures at a cost to switchers. Yet a cross 
border switching service would have considerable benefits. About 12.3 million EU citizens above the 
age of 15 permanently reside in another Member State and a switching service would facilitate their 
mobility. Considering the high price dispersion of payment accounts, all consumers – mobile and non-
mobile – would have the opportunity to shop around and save money by opening a payment account in 
another Member State.  

4. 

INTERLINKS 

Access to a payment account is essential in the modern economy. In a truly functioning internal market, 
access  should be available across domestic borders,  anywhere in the EU. If an EU citizen from Poland 
moves  to  the  UK,  but  is  unable  to  open  an  account,  transparent  information  on  fees  and  an  effective 
switching process will be of no value to them.  
The Commission inquiry into the retail banking sector27 found that low levels of customer mobility was 
directly  related  to  higher  bank  profitability  and  that  the  impact  of  customer  mobility  in  the  payment 

21  http://ec.europa.eu/internal_market/finservices-retail/docs/baeg/switching_principles_en.pdf 
22  Consumer  Market  Study  on  the  consumers’  experiences  with  bank  account  switching  with  reference  to  the  Common 

Principles on Bank Account Switching, GfK, January 2012. 
Ibid. 

23 
24  Consumers' views on switching service providers, Eurobarometer 243, European Commission, p. 18. 
25  Cf. footnote 21; Tarifs et mobilité bancaires: le désolant palmarès des Banques, UFC Que Choisir, 2010; Kontowechsel: 

Wie funktioniert er?, VKI, March 2010. 
ICB Final report recommendations, ICB, September 2011, p. 220. 

26 

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account  market  on  market  power,  (measured  on  total  retail  banking  profitability),  was  such  that  a  1% 
increase  in  market  churn28  gave  rise  to  a  corresponding  similar  decrease  in  banks'  pre-tax  profitability 
ratio.  

Opaque fee structures raise barriers to a smooth switching process, making it difficult or even impossible 
in the case of cross-border comparisons, to seek out a better product. The actual switching of accounts can 
only  take  place  once  the  consumer  has  made  a  choice  of  product,  based  on  transparent  and  easy  to 
understand fee information. Barriers to switching can therefore be the final straw for many consumers at 
the end of a long process. Put another way, cross-border fee transparency and/or switching mechanisms 
cannot be truly effective unless barriers to accessing markets across borders are removed for consumers. 

Combined, the problems identified in these three areas, financially exclude certain consumers and inhibit 
consumer  mobility,  competition  and  efficiency  in  payment  account  markets.  However,  they  also  create 
very  practical  problems  in  terms  of  time,  effort  and  financial  costs  for  consumers  and  industry  alike 
seeking  to  move  across  the  EU,  creating  impediments  to  growth  and  undermining  the  flexibility  of  the 
economy. 

5. 

OBJECTIVES 

The  over-arching  objective  of  this  initiative  is  to  create  an  efficient  and  competitive  Single  Market 
(Article 114.1 of the Treaty) with a high level of consumer protection (Article 114.3 of the Treaty) that 
fosters  balanced  economic  growth  with  greater  economic  inclusion.  The  objectives  of  this  Impact 
Assessment are described in the table below. 

• 
• 
• 
• 
• 

To enhance consumer confidence 
To broaden consumer choice both in terms of the quality of the products available and in terms of price reductions 
To facilitate financial inclusion and thereafter customer mobility 
To facilitate the cross-border activity of payment account providers 
To ensure a level playing field between market actors 

General 

Specific 

Access to basic account services 
To facilitate access to basic account services 
(not oblige everyone to have a payment  
account) 

Presentation and ease of comparison of bank fees 
To ensure that EU consumers receive clear, complete and 
comparable information on bank fees 

Switching of payment accounts 
To ensure that EU consumers are able to  
switch payment accounts with ease and  
in a timely manner. 

Operational 

(cid:131) 
(cid:131) 

(cid:131) 

(cid:131) 

(cid:131) 
(cid:131) 
(cid:131) 
(cid:131) 
(cid:131) 

(cid:131) 
(cid:131) 

(cid:131) 

(cid:131) 
(cid:131) 
(cid:131) 

Reduce the number of unbanked Europeans by 6.4  million by 202029 
Ensure access to all basic payment means for all consumers with basic 
payment accounts 
Facilitate cross-border access to basic banking services for 3.5 million 
consumers by 202030 
Improve consumers' awareness on basic payment accounts 

Consumers are able to understand bank offers and assess value for money 
Payment account offers are easily comparable 
Help consumers choosing the offer best matching their needs 
Increase consumers awareness of charges actually paid 
The burden of switching to consumers is reduced 

Switching is a smooth and easy process 
Consumers are assisted and informed of the switching process in an 
adequate manner 
The number of misdirected/missed payments during switching process is 
reduced to less than 5% of recurrent transactions 
The direct financial costs of switching to consumers is reduced 
The duration of switching process is maximum 14 days 
The mobility of payment account users is increased 

27  Report on the retail banking sector inquiry, SEC(2007) 106, European Commission, 31.1.2007; 

http://ec.europa.eu/competition/sectors/financial_services/inquiries/sec_2007_106.pdf 

28  Defined as the share of customers who change providers in a given year. 
29   EU 2020 strategy aims to reduce a number of poor and socially excluded by at least 20 million by 2020 through, among 

others, improved access to essential services and tackling financial exclusion. 
http://ec.europa.eu/social/main.jsp?catId=751&langId=en 

30   Ibid. 

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NEED FOR EU ACTION 

6. 
As  payment  accounts  are  the  financial  services  product  most  likely  to  be  purchased  cross-border,31 
identifying adequate solutions to the problems outlined above is vital. The consequences of inaction are 
serious,  including  the  inhibited  development  of  a  fully-functioning  internal  market  with  significant 
impacts upon consumers, business and the wider economy. 

The  regulatory  and  self-regulatory  initiatives  discussed  in  section  2  above  have  failed.  Despite  public 
announcements that a review of the account markets was underway32, there are few, if any, initiatives in 
the pipeline at the national level to improve the situation. The Commission has committed to acting in the 
event of a failure of these initiatives.  

According  to  the  subsidiarity  principle,  EU  action  may  only  be  taken  if  the  envisaged  aims  cannot  be 
achieved by Member States alone. Whilst it may be the case that EU intervention cannot easily address 
some  of  the  more  intangible  features  of  cross-border  take-up  of  banking  services,  such  as  language  or 
distance, EU intervention is justified to achieve the outlined objectives for several reasons: 

To improve the proper functioning of the internal market and avoid the distortion of competition in 
retail banking  
An EU initiative will best address factors that prevent the pursuit of business or  raise the cost of doing 
business in another Member State relative to the costs faced by domestic providers. This will maximise 
efficiency  gains,  prevent  the  creation  of  new  barriers  and  strengthen  the  retail  financial  market.  The 
current  uneven  playing  field  between  market  actors  results  in  reduced  competitive  rivalry  and  missed 
opportunities. This is compounded by low customer mobility and inefficient switching mechanisms that 
create  obstacles  to  market  entrants  gaining  new  clients.  Action/inaction  from  Member  States  alone  is 
likely to result in different sets of rules, leading to uncompetitive markets and unequal levels of consumer 
protection in the EU. Finally a common approach is needed to define requirements for the presentation of 
bank fees in a comparable manner that encompasses both domestic and cross-border markets as separate 
standards focussing only on cross-border activity may further fragment domestic markets. 

To  empower  consumers  by  enabling  them  to  make  informed  choices  and  enable  them  to  take 
advantage of the single market 
The problems identified lead to consumer detriment through low consumer confidence, higher costs and 
reduced customer mobility, both domestically and cross-border, and thus represent a cost for society as a 
whole.  In  a  competitive  and  efficiently  functioning  single  market  with  a  high  level  of  consumer 
protection,  all  EU  citizens  will  have  the  tools  necessary  to  search  for  the  best  product  for  their  needs 
anywhere within the EU. 

Allow  all  European  citizens  access  to  essential  services  and  the  opportunity  to  benefit  from  the 
single market by promoting economic and financial inclusion  

Without EU action it will be difficult to bring the advantages of the single market to all EU citizens. A 
level  playing  field  at  EU  level  will  help  consumers  reap  the  full  benefits  of  the  integration  of  the 
European financial sector by facilitating financial inclusion enabling all consumers to fully benefit from 
the  internal  market  (for  example  by  participating  in  e-commerce  and,  therefore,  in  the  digital  market, 
including more competitive cross-border goods and services). Access to essential services including basic 
account  services33  contribute  to  active  inclusion  strategies  aimed  at  the  re-integration  of  the  people 
furthest  from  the  labour  market.  Therefore,  it  forms  part  of  the  delivering  actions  identified  by  the 

31  Cf. footnote 9. 
32  Cf. footnote 4. 
33  Together with various enabling services, such as healthcare, childcare, social housing, or life-long-learning. 

8 

 
 
                                                            
European Platform against Poverty and Social Exclusion, one of the flagship initiatives of Europe 2020 
aimed at achieving inclusive growth in the EU.  

An initiative based on Article 114 of the TFEU would help to achieve the objective of the establishment 
and  proper  functioning  of  the  internal  market  with  a  high  level  of  consumer  protection  and  to  avoid 
distortion  of  competition  in  the  field  of  retail  banking.  It  will  respect  the  principles  of  subsidiarity  and 
proportionality,  as  it  is  clear  that  the  envisaged  aims  cannot  be  achieved  by  Member  States  alone.  EU 
intervention in the areas of payment accounts is justified on this basis. 

7. 

POLICY OPTIONS, IMPACT ANALYSIS AND COMPARISON 

The tables below summarise the policy options. The retained options are highlighted. 
7.1 
Option 
1 
2 
3 

Access to basic account services 
Summary 
No EU action 
Ensure that the provisions of the Recommendation are applied. 
Modify the provisions of the Recommendation relative to the beneficiaries 
A: Introduce a universal right to a basic payment account 
B: Introduce a right to a basic payment account for national residents 
C: Introduce a right to a basic payment account to non-residents with a link to the country where they wish to open an account 
Improve the features of the basic payment account 
A: Enlarge the list of basic services to include internet banking and online purchasing 
B: Enlarge the list of basic services to include a small overdraft or a ‘buffer’ facility 
C: Indicate a minimum account balance that cannot be seized 
D: Ensure that the features of the payment account are not of a discriminatory nature. 

4 

It  is  crucial  to  ensure  access  to  a  basic  payment  account  for  all  citizens,  particularly  vulnerable 
consumers. The introduction of Option 2 would be most effective for both residents and non-residents. It 
is assumed that Options 4A, B and C would attract a number of unbanked consumers and improve access 
to different means of payment because each of them provides for an additional account feature. Option 
4A  would  be  most  likely  to  attract  additional  consumers  and  Option  4D  would  also  attract  many 
unbanked consumers, and especially mobile consumers, since it would allow for the account to be used in 
the  same  way  all  over  the  EU.  The  combination  of  Options  2,  4A  and  4D  are  the  most  effective  in 
tackling the problems in the market and achieving the objectives set. Options 4A and 4D are in line with 
the European Parliament recommendations, “The legislation should enable the user of a basic payment 
account to make any essential payment transactions such as receiving income or benefits, paying bills or 
taxes  and  purchasing  goods  and  services  via  both  physical  and  remote  channels  using  mainstream 
national systems.”34 

7.2 

 Presentation and ease of comparison of bank fees 

Option 

Summary 

1 

2 

3 

No EU action 

Introduce a standard price list as part of account opening procedures. Fees common to all Member States would be 
identified at EU level and supplemented nationally to cover the 20 most representative fees or at least 80 % of key 
charges incurred. 

Introduce the requirement to develop glossaries for bank fee terminology 
A: Non-harmonised terminology 
B: Not based on fully harmonised terminology 

34  Cf. footnote 15. 

9 

 
 
                                                            
4 

5 

6 

7 

8 

9 

Introduce the requirement to set up independent fee comparison websites at Member State level 
A: a single official website in each Member State  
B: Comparison sites licensed under an accreditation scheme 

Introduce the requirement to provide representative examples of the cost of holding a payment account 
A: Banks set up own representative examples 
B: Member States prescribe representative examples 

Establish customer usage profiles and provide a cost simulation to prospective personal current account holders 
A: Banks set up own customer profiles 
B: Member States prescribe customer profiles 

Introduce EU standardised forms for the provision of ex-ante information on fees 

Introduce an obligation for banks to provide ex-post information on fees incurred 

Introduce EU standardised forms for the provision of ex-post information on fee 

Option  2  obliges  the  provision  of  lists  of  account  fees.  These  would  be  developed  at  EU  level  and 
supplemented at national level, using standardised terminology. This would facilitate the comparison of 
different  offers  and  empower  consumers  to  verify, understand  and  compare  fees.  It  will  contribute  to  a 
level playing field between providers competing in the market as all EU providers would need to comply 
with the same requirements. Option 8 is considered effective, especially if packaged with Option 2, as it 
will provide ex-post information on the same fee items, which will allow consumers to understand their 
fees and empower them to make the right choices. With the information provided through Options 2 and 
8, Option 4B, the comparison website tool, reduces search and switching costs to consumers and allows 
them to compare account offers. Option 4B is more effective for Member States than 4A, as it does not 
force Member States to set up a new website, but reinforces existing websites. 

7.3 

Payment account switching 

Option 
1 
2 
3 

4 

5 

Summary 
No EU action 
Ensure that the switching services follow the Common Principles 
Improve the effectiveness of the Common Principles 
A: Improve the existing Common Principles at domestic level 
B: Broaden the scope of the improved Common Principles to EU-wide cross-border switching 
Introduce an automatic redirection service for all receipts and payments 
A: Domestic 
B: EU 
Introduce payment account portability 
A: Domestic  
B: EU 

The most effective long-term set of options would be Option 3B combined with Option 5B. This would 
represent  an  efficient  step  towards  a  better  integrated,  functioning  internal  market.  However,  further 
research should be conducted to analyse the technical possibilities and risks related to the introduction of 
5B.  For  this  purpose,  a  mandate  could  be  given  to  European  Banking  Authority  to  engage  in  further 
analysis  to  elaborate  a  technically  feasible  and  efficient  way  within  a  certain  time  period.  The  current 
preferred option is Option 3B. 

8. 

THE PACKAGE OF POLICY OPTIONS 

The rationale for selecting a 'package' comprising policy options covering the three areas covered by 
this  impact  assessment  is  strictly  and  fundamentally  linked  to  the  general  objectives.  Only  a 
combination  of  actions  in  the  three  areas  can  establish  the  right  to  a  basic  payment  account  to  EU 
citizens, provide common standards to ensure transparent and comparable bank account fees and make 

10 

 
 
 
(cross-border) switching of bank accounts easier. The impact assessment considers four packages that 
group policy options reflecting different degrees of EU intervention. The resulting preferred package 
group  the  preferred  sets  of  policy  options  identified  for  each  of  the  three  areas  in  section  7  above. 
Above all options assessed, this package is considered to better enhance the functioning of the internal 
market, ensure a high degree of equivalent consumer protection to all EU citizens and foster economic 
growth alongside greater financial inclusion. 

A package of options that omits even one of these elements may risk creating a single market that is 
not accessible to all EU citizens, further entrenching market fragmentation, endangering competition 
and restricting efficiency gains.  

9. 

CUMULATIVE IMPACTS 

The three tables below provide a disaggregated overview of costs and benefits for the preferred options in 
each  of  the  three  areas.  Several  types  of  costs  generated  by  the  preferred  set  of  options  for  credit 
institutions and Member States are expected to be cumulative (e.g. updating of IT systems and cumulating 
recurring  costs  of  additional  compliance  staff).  The  methodology  to  assess  the  efficiency  of  options 
considers  both  quantified  and  non-quantified  costs  and  benefits  to  stakeholders,  as  described  in  this 
section. 

Access to a basic payment account 

Total EU benefits 
(million EUR/year) 

Consumer: 
One off benefits 
Recurring annual benefits 
Payments services provider: 
Recurring annual benefits 
Member State: 
One off benefits 
Recurring annual benefits 
Enterprises 
Recurring annual benefits 

Option 2 

542-2711 

542-2711 
18-89 
18-89 
18-89 

18-89 
32-160 
32-160 

Option 
4(A) 
236-1179 
Non quantifiable 
236-1179 
2-11 
2-11 
2-11 
Non quantifiable 
2-11 
16-80 
16-80 

Option 
4(D) 
68-339 

68-339 
-1.8 to -9 
-1.8 to -9 
2-11 

2-11 
4-20 
4-20 

Total EU costs  
(million EUR/year) 

Consumer: 
One off costs 
Recurring annual costs 
Payments services provider: 
One off costs 
Recurring annual costs 
Member State: 
One off costs  
Recurring annual costs 
Enterprise: 

Option 2 

108-542 
0 
108-542 
71-356 
Not  
71-356 
3.02 
1.13 
1.89 
0 

Option 
4(A) 
22-108 
0 
22-108 
15-74 
0 
15-74 
0 
0 
0 
0 

Option 
4(D) 
22-108 
0 
22-108 
19-94 
0 
19-94 
0.38 
0.14 
0.24 
0 

Ease of comparison of bank fees and requirements covering presentation 
Payment account switching  

Total EU benefits 
(million EUR 2013-2022) 

Consumer benefits:   
Change switching behaviour 
Better account management 
Credit institution: 
Cross-border cost savings 
Business opportunities 

Total EU costs  
(million EUR 2013-2022) 

Credit institution: 
one-off 
recurring 

Member State: 
one-off 
recurring 

Option 2 

Option 4.B 

Option 8 

584.87 

731.08 

1 462.16 
2 702.57 

Not quantifiable 

Not 
quantifiable 

Not quantifiable 

95.95-163.03 
183.17-245.40 

0.32-0.65 
4.77-9.53 

192.42-326.31 
260.37-492.45 

0.05-0.08 
0.06-1.17 

0.36-0.66 
3.48-6.74 

0.07-0.11 
0.81-1.59 

Total EU benefits 
(million EUR 2013 -2022) 

Consumer: 
Change switching behaviour 
Reduction direct/indirect costs 
Credit institution: 
Cross-border cost savings 
Business opportunities 

Total EU costs 
(million EUR) 

Credit institution: 
one-off 
recurring 

Member State: 
one-off 
recurring 

Option 3B 

3 655.4 
Marginal 

Not quantifiable 

67 – 129 
2 041 – 2 649 

3 
19 

The assessment of a preferred policy instrument favoured a binding policy instrument for all areas. This 
assessment does not change when preferred options are packaged. On a cumulative basis the three sets of 
preferred options are complementary and do not result in diverging impacts.  

11 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
The package of preferred options will make a real difference for consumers. The measures on access will 
reduce  the  number  of  unbanked  citizens  while  at  the  same  time  creating  a  fully  functioning  internal 
market  for  payment  accounts  that  is  efficient  and  competitive.  Consumers  will  benefit  from  improved 
access  to  their  funds  regardless  of  their  geographic  location;  experience  an  increased  level  of  security 
through  lower  levels  of  cash  transactions;  an  increased  choice  of  goods  and  services  where  electronic 
payments  are  obligatory;  the  possibility  to  access  employment  and  accommodation  more  easily  and  a 
reduced  sense  of  financial,  economic  and  social  exclusion.  A  strong  positive  effect  on  consumer 
confidence  will  underpin  demand  for  payment  accounts  and  encourage  consumer  mobility  both  at 
national and cross-border level. 

The expected effects of competition will include cost efficiencies for credit institutions (since they could 
implement  the  same  IT  systems,  processes,  staff  training  procedures  etc.  in  all  Member  States  within 
which  they  operate,  resulting  in  economies  of  scale),  easier  market  entry  for  foreign  providers,  and 
greater  potential  for  market  expansion  of  competitive  providers.  Non-quantifiable  benefits  for  credit 
institutions  will  include:  an  increased  customer  base  to  which  to  market  other  products  (e.g.  home 
insurance); the reduced cost of and risks from cash based payments; and the benefits from a contribution 
to capital and funding. 

The  preferred  policy  options  will  entail  costs  for  credit  institutions,  but  the  overall  impact  will  be 
reasonable. Providers are projected to incur more costs – or at least quantifiable costs – than benefits, in 
the  short  term.  These  costs  will  be  limited  by  several  factors.  First,  a  number  of  the  policy  options  are 
already implemented in several Member States. Second, substantial synergies are expected between the 
different  policy  options  (e.g.  adapting  IT  systems,  internal  communication  and  staff  training).  Third, 
providers would be able to cover their costs by adjusting prices of payment accounts. Fourth, the more 
accounts opened over time, the lower the incremental costs of access, switching and transparency. 

Member States and wider society as a whole would benefit from lower costs for social security payments 
or less fraud related to benefits and tax. More generally, promoting competitive banking markets would 
improve  the  efficiency  of  the  single  market,  which,  at  a  time  of  economic  crisis,  would  be  particularly 
valuable.  These  benefits  would  reinforce  each  other  improving  and  stimulating  consumer  and  business 
confidence thus stimulating growth.  

This  proposal  has  no  implication  for  the  budget  of  the  EU  or  those  of  EU  agencies.  This  package  will 
benefit EU businesses significantly. They are unlikely to incur any costs but could benefit substantially 
from improved access to payment accounts. The preferred options will create the conditions for a bigger 
market  for  their  goods  and  services.  Moreover,  non-discriminatory  instruments  and  online  facilities  in 
relation to payment account services would trigger a potential increase in cross-border trade. 

The  main  administrative  burden  will  arise  from  the  internal  processes  of  credit  institutions  being 
adapted to cater for information requirements for both consumers and authorities. This comprises mainly 
the  cost  of  adapting  information  systems  and  materials.  There  will  be  the  cost  to  Member  States  of 
organising  and  running  public  information  campaigns  to  raise  consumer  awareness  of  their  rights.  The 
administrative burden placed on consumers should reduce as they will no longer need to provide as much 
documentation and evidence to open an account. 

10. 

CONCLUSION 

A  legislative  package  on  payment  accounts  that  accommodates  national  specificities  while  ensuring 
access  to  basic  payment  services,  the  comparability  and  transparency  of  account  fees  and  facilitates 
payment  account  switching  will  meet  the  objectives  set  out  in  this  impact  assessment  and  satisfy  the 
resolutions  of  the  European  Parliament  and  the  call  for  action  in  the  Single  Market  Act  II.  The 
Commission should review the appropriateness and effectiveness of the package after its implementation. 

12 

 
 
This  review  could  include  a  public  consultation,  mystery  shopping  exercises  and  analysis  of  consumer 
complaints. Regard would also be given to indicators such as the number of unbanked consumers, use of 
electronic payment methods and the number of consumers switching. 

13