REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL on the application of Directive 2014/92/EU 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: 2023-05-12
Institutions: Directorate-General for Financial Stability, Financial Services and Capital Markets Union, European Commission
Subjects: account, bank charges, banking system, equal treatment, financial services, financial transparency, intra-EU payment, single market

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 12.5.2023  COM(2023) 249 final  REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL on the application of Directive 2014/92/EU 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      
 
 
TABLE OF CONTENTS 

1. 

INTRODUCTION ......................................................................................................................... 3 

2.  TRANSPARENCY AND COMPARABILITY OF PAYMENT ACCOUNT FEES ............... 4 

3.  ACCESS TO PAYMENT ACCOUNTS ...................................................................................... 5 

3.1 

3.2 

3.3 

Non-discriminatory access to payment accounts ................................................................ 5 

Access to a PABF ................................................................................................................... 6 

List of services ...................................................................................................................... 10 

4.  SWITCHING OF PAYMENT ACCOUNTS ............................................................................ 11 

5.  ASSESSMENT OF POSSIBLE FURTHER MEASURES ON SWITCHING ...................... 13 

5.1 

5.2 

Feasibility of extending the switching service in Article 10 to cross-border switching . 13 

Feasibility of a framework for automated redirection of payments ............................... 13 

5.3 
Assessment of the costs and benefits of implementing full EU-wide portability of 
payment account numbers .............................................................................................................. 14 

6.  EFFECTIVENESS OF EXISTING MEASURES AND THE NEED FOR ADDITIONAL 
MEASURES TO INCREASE FINANCIAL INCLUSION AND TO ASSIST VULNERABLE 
PEOPLE IN RELATION TO OVER-INDEBTEDNESS ................................................................ 15 

7.  EXAMPLES OF BEST PRACTICES AMONG MEMBER STATES FOR REDUCING 
CONSUMER EXCLUSION FROM ACCESS TO PAYMENT SERVICES. ............................... 16 

8.  CONCLUSION ............................................................................................................................ 17 

1 

 
 
 
 
 
ABBREVIATIONS  

AML 
AML/CFT 
AMLD  
BIC 
EBA 
FID 
IBAN   
PAD 
PABF   
PSP 

Anti-money laundering 
Anti-money laundering and countering the financing of terrorism 
Anti-Money Laundering Directive (Directive (EU) 2015/849) 1 
Bank identifier code 
European Banking Authority 
Fee information document 
International bank account number 
Payment Accounts Directive (Directive 2014/92/EU) 2 
Payment account with basic features 
Payment Service Provider 

1 Directive (EU) 2015/849 of the European Parliament and of the Council of 20 May 2015 on the prevention of 
the use of the financial system for the purposes of money laundering or terrorist financing, amending Regulation 
(EU) No 648/2012 of the European Parliament and of the Council, and repealing Directive 2005/60/EC of the 
European  Parliament  and  of  the  Council  and  Commission  Directive  2006/70/EC  (OJ  L  141,  5.6.2015,  p.  73–
117). 
2 Directive 2014/92/EU of the European Parliament and of the Council of 23 July 2014 on the comparability of 
fees related to payment accounts, payment account switching and access to payment accounts with basic features 
(OJ L 257, 28.8.2014, p. 214–246). 

2 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                           
1.  INTRODUCTION 

The Payment Accounts Directive (the PAD or the Directive) was adopted on 23 July 2014 as 
part  of  the  EU’s  efforts  to  enhance  the  transparency  and  comparability  of  fees  charged  to 
consumers  on  their  payment  accounts;  switching  payment  accounts;  and  opening  and  using 
PABFs in the EU. 

The  PAD  entered  into  force  on  17  September 2014.  The  implementing  technical  standards 
and  regulatory  technical  standards  3  for  the  implementation  of  the  Directive’s  transparency 
requirements entered into application in October 2018.  

Member  States  had  until  18 September 2016  to  transpose  and  publish  the  laws,  regulations 
and  administrative  provisions  necessary  to  comply  with  the  Directive.  However,  only  9 
Member  States  4  had  declared  complete  transposition  within  (or  shortly  after)  the  deadline. 
The  European  Commission  opened  infringement  proceedings  against  the  remaining  18 
Member  States  for  non-communication  of  transposition.  All  of  these  non-communication 
infringement  cases  were  closed  after  the  Member  States  notified  the  Commission  that  they 
had  completed  their  transposition  (and  the  Commission  had  assessed  and  confirmed  this 
transposition).  The  Commission  has  not  yet  launched  any  infringement  procedures  for  non-
compliance with the PAD.  

This  report  has  been  adopted  in  response  to  Article 28  of  the  Directive,  which  requires  the 
Commission  to  provide  a  report  on  the  application  of  the  Directive  by  18  September  2019. 
The report’s issue has been delayed due to the need to ensure that the Directive had been in 
application for a certain amount of time. The Commission has in parallel adopted the report 
required by Article 27 of the Directive (the Article 27 report).  

The  Commission  launched  two  studies  to  support  this  report.  The  first  study  (the  Deloitte 
Study 1 5) evaluates the Directive and provides input for the assessment of the application of 
the  Directive.  It  covered  16  Member  States  6.  The  second  study  (the  Deloitte  Study  2 7) 
assesses  possible  new  tools  to  facilitate  cross-border  switching  and  serves  as  the  basis  for 
Chapter 5, which assesses possible additional measures to facilitate switching. Member States 
have  also provided important  data/input  for  this  report.  The  Commission  nevertheless faced 
some  difficulties  when  preparing  this  report –  particularly  the  lack  of  available  and 

3 “Commission Delegated Regulation (EU) 2018/32 of 28 September 2017 supplementing Directive 2014/92/EU 
of  the  European  Parliament  and  of  the  Council  with  regard  to  regulatory  technical  standards  for  the  Union 
standardised terminology for most representative services linked to a payment account (OJ L 6, 11.1.2018, p. 3–
25)”; “Commission Implementing  Regulation (EU) 2018/34 of 28 September 2017 laying down implementing 
technical standards with regard to the standardised presentation format of the fee information document and its 
common  symbol  according  to  Directive  2014/92/EU  of  the  European  Parliament  and  of  the  Council  (OJ  L  6, 
11.1.2018,  p.  37–44)”;  “Commission  Implementing  Regulation  (EU)  2018/33  of  28  September  2017  laying 
down implementing technical standards with regard to the standardised presentation format of the statement of 
fees and its common symbol according to Directive 2014/92/EU of the European Parliament and of the Council 
(OJ L 6, 11.1.2018, p. 26–36)”. 
4 All references to Member States in this report refer to the 27 EU Member States.  
5 Deloitte, Study on the Payment Accounts Market, 2020, https://op.europa.eu/en/publication-detail/-
/publication/0854f727-6117-11eb-8146-01aa75ed71a1/language-en.  
6 Belgium, Bulgaria, Czechia, Finland, France, Germany, Greece, Hungary, Ireland, Italy, Latvia, Luxembourg,  
Netherlands, Poland, Spain and Sweden. 
7  Deloitte, Study on tools designed to facilitate switching and cross-border opening of payment account on the 
EU  payment  accounts  market,  2021,  https://op.europa.eu/en/publication-detail/-/publication/70d1fcb7-f338-
11eb-aeb9-01aa75ed71a1. 

3 

 
 
                                                           
comparable data. The objective of the PAD is to foster  the single market  for retail financial 
services  and  in  particular  for  payment  accounts.  The  Directive  aimed  to  achieve  this  by  (1) 
creating transparency and ensuring comparability of payment account fees; (2) ensuring that 
consumers  have  access  to  payment  accounts  (with  basic  features)  and  (3)  facilitating  the 
switching  of  payment  accounts.  The  following  chapters  assesses  the  application  of  the 
Directive as well as the additional elements required in Article 28.  

2.  TRANSPARENCY  AND  COMPARABILITY  OF  PAYMENT  ACCOUNT 

FEES  

Article 7 of the Directive requires Member States to ensure that consumers have access, free 
of  charge,  to  at  least  one  comparison  website.  Article 7(3)  sets  out  a  list  of  requirements, 
namely  that  the  comparison  website  must  be  run  in  an  independent  manner;  disclose  the 
identity  of  the  website’s  owner;  set  out  clear  and  objective  criteria  for  the  comparison;  use 
plain  and  unambiguous  language;  be  up  to  date;  cover  a  significant  part  of  the  market;  and 
provide an effective procedure to report incorrect information on published fees.  

After  consulting  Member  States  with  the  relevant  Expert  Group  (GEGREFS),  the 
Commission has the overall impression that the requirements currently listed in Article 7(3) of 
the Directive are sufficient  and that there  is  no urgent  need to  amend the list.  However, the 
Deloitte Study 1 has – on the basis of a review of the identified websites that comply with the 
requirements  of  the  Directive  –  pointed  out  that  the  following  two  requirements  listed  in 
paragraph 3 are not fully functioning: (1) the requirement to set out the objective criteria for 
the comparison; and (2) the requirement to report incorrect information on published fees. In 
addition, the information on the last time a website is updated has posed problems. That said, 
the  issues  signalled  by  the  Deloitte  Study  1  relate  more  to  the  operational  aspect  of  the 
website than to the list itself. In this context, the Commission will continue to closely monitor 
the situation to ensure that the compliant Member State websites do in fact comply with the 
requirements laid down in Article 7(3) of the Directive. 

Article 28(3)  of  the  Directive  requires  the  report  to  assess  whether  there  is  a  need  for 
accreditation of comparison websites. The general feeling among Member States was that this 
would not add much value, mainly because the current compliant comparison tables is public 
and therefore  intrinsically  trustworthy.  In addition, the  certification process  would be costly 
and  time-consuming.  No  issues  with  the  comparison  website  have  been  registered  in  most 
Member States, so there is no need to amend the current system. 

With regard to measures on ‘packaged offers’, Article 4 on the FID, Article 5 on the statement 
of fees and Article 8 refer to the concept of packages. The Deloitte Study 1 observed  on the 
basis  of  collected  data  that  stakeholders  have  interpreted  ‘package’  in  two  distinct  and 
different ways: either (i) a combination of a payment account with the various services linked 
to it that enable its use (e.g. a card or an overdraft); or (ii) a combination of a payment account 
with  other  types  of  financial  products  (e.g.  insurance  and  mortgages).  In  this  context, 
16 Member States (BE, BG, DE, IE, ES, IT, LV, LU, HU, MT, NL, PL, PT, RO, SI and SK) 
expressed  support  for  the  idea  of  introducing  a  definition  of  the  term  ‘package’  into  the 
Directive in  order to  bring additional clarity  (especially in  instances of tying and bundling). 
However,  some  other  Member  States  cautioned  against  such  an  approach,  arguing  that  the 
term  is  already  sufficiently  clear  and  that  it  would  make  more  sense  to  address  the  issue  in 
Article 4 of the Directive. In this context, with regard to Article 4 on the FID, the section of 
the FID dedicated to ‘packages of services’ could be too long in some cases. This is because 

4 

 
 
some  banks  mention  several  packages  in  their  FID  and  this  has  resulted  in  the  FID  being 
several  pages  long  –  thus  defeating  the  purpose  of  having  a  short  stand-alone  FID.  They 
therefore believe that any possible changes to the concept of packages should be targeted to 
Article 4.  More  broadly  with  regard  to  Article  4,  an  unintended  consequence  has  been  the 
duplication  of  documents  on  fee  levels  of  payment  accounts  in  those  Member  States  where 
documents with the same information already existed. In fact, on the basis of Member States 
comments,  the  most  important  unintended  consequence  of  this  has  been  the  duplication  of 
documents  on  fee  levels  of  payment  accounts  in  Member  States  where  documents  with  the 
same information already existed. The Commission has taken good note of these issues  and 
will keep the suggestions received in mind in the eventual revision of the Directive. 

3.  ACCESS TO PAYMENT ACCOUNTS   

3.1.  Non-discriminatory access to payment accounts  
Article 15  of  the  Directive  requires  Member  States  to  ensure  that  credit  institutions  do  not 
discriminate  against  consumers  legally  resident  in  the  EU  by  reason  of  their  nationality  or 
place of residence (or by reason of any other ground referred to in Article 21 of the Charter of 
Fundamental  Rights  of  the  European  Union)  when  those  consumers  apply  for  or  access  a 
payment  account  within  the  EU.  Article 15  also  states  that  the  conditions  applicable  to 
holding a PABF must not be in any way discriminatory.  

Member  States  have  either  specifically  transposed  the  non-discrimination  provision  or  have 
concluded that this point was already covered by their existing legislation. However, only a 
few Member States have integrated the non-discrimination principle into their national law so 
as  not  only  to  cover  the  access  to  payment  accounts  but  also  to  specifically  cover  the 
applicable conditions. 

Despite  this  rule,  access  to  payment  accounts  may  still  be  different  for  consumers  of  a 
different nationality or in a different place of residence. For example, a requirement to present 
a  specific  national  identity  document  may  affect  consumers  from  other  Member  States 
differently.  As  shown  by  the  Deloitte  Study  1  and  indicated  by  complaints  received  by  the 
Commission,  difficulties  may  also  exist  as  regards  the  cross-border  opening  of  payment 
accounts, not least as regards cross-border online opening which is sometimes not available to 
consumers from other Member States 8. The Commission has also received complaints about 
different levels of fees for non-residents in the Member State.  Charging higher fees for PABF 
for non-residents would be discriminatory if the additional fees are not based on objectively 
justified costs.  

These  different  requirements  may  not  only  lead  to  a  different  treatment  in  many  cases,  but 
may also affect access to payment accounts, including to PABFs. Such cases are described in 
more detail in Section 3.2. 

8  According  to  Deloitte  Study  1,  some  banks  consider  that  they  are  not  able  to  fulfil  their  requirements  on 
AML/DFT, or to face the required level of complexity or costs. 

5 

 
 
 
 
 
 
 
                                                           
3.2.  Access to a PABF 

  The right to a PABF  
In order to foster financial inclusion, Article 16 of the Directive establishes the right of access 
to  a  PABF  for  all  consumers  legally  resident  in  the  EU.  This  includes  consumers  with  no 
fixed address, asylum seekers and consumers who  have been refused a residence permit but 
whose  expulsion  is  impossible  for  legal  or  factual  reasons  9.  Article 16(1)  requires  Member 
States  to  ensure  that  PABFs  are  offered  to  consumers  either  by  all  credit  institutions  or  a 
sufficient number of credit institutions to guarantee access thereto for all consumers in their 
territory. 

This right to a PABF has been transposed by the Member States in their national legislation. 
In  most  Member  States,  a  PABF  is  offered  as  a  separate  product  distinct  from  a  standard 
payment account. In some Member States 10, however, (some or all) credit institutions do not 
offer a PABF as a separate product but prefer to offer a standard account to all consumers.  

Most  Member  States  require  all  credit  institutions  that  offer  payment  accounts  to  offer  a 
PABF, but  a few Member States  11 require only some credit institutions which fulfil certain 
criteria to offer a PABF. However, such obliged credit institutions do generally provide wide-
ranging  access.  In  addition,  other  payment  services  providers  also  offer  PABFs  in  some 
Member States.  

Sectoral and consumer organisations therefore broadly agree that consumers in their country 
have sufficient access to PABFs 12.  

Article 16 provides for a number of (possible) derogations to this right to a PABF. In practice, 
the  most  important  derogation  concerns  AML.  Article 16(4)  of  the  PAD  requires  Member 
States to ensure that credit institutions refuse an application if opening such an account would 
result  in  an  infringement  of  the  provisions  on  the  prevention  of  money  laundering  and  the 
countering of terrorist financing laid down in Directive 2005/60/EC 13. This can conflict with 
the  right  to  a  PABF  and  the  interaction  may  not  be  fully  clear.  Recital  34  of  the  PAD 
underlines  that  AML  rules  should  not  be  used  as  a  pretext  for  rejecting  commercially  less 
attractive  consumers.  No  other  general  EU-level  guidance  on  the  interlinkages  between  the 
different rules currently exists.  

9  This  right  to  a  PABF  has  been  a  crucial  instrument  to  ensure  the  financial  inclusion  of  Ukrainian  refugees. 
Once Ukrainian refugees received the temporary protection, they had the right of access to a PABF. 
10  According  to  Deloitte  Study  1,  in  five  Member  States  there  is  no  distinction  between  standard  payment 
accounts and payment accounts with basic features (see for further details Figure 31). 
11  Member  States  where  only  some  credit  institutions  offer  PABFs:  Greece,  Croatia,  Cyprus,  Luxembourg, 
Malta, Netherlands, Slovakia (See for further details the Article 27 report). 
12 100% of sector organisations and 70% of consumer organisations agreed that all consumers in their country 
have access to PABF (see for further details Figure 5, Annex D of Deloitte Study 1).  
13 Directive  2005/60  has  since  been  repealed  and  replaced  by  Directive  (EU)  2015/849  of  the  European 
Parliament  and  of  the  Council  of  20  May  2015  on  the  prevention  of  the  use  of  the  financial  system  for  the 
purposes of money laundering or terrorist financing, amending Regulation (EU) No 648/2012 of the European 
Parliament  and  of  the  Council  and  repealing  Directive  2005/60/EC  of  the  European  Parliament  and  of  the 
Council and Commission Directive 2006/70/EC (OJ L 141, 5.6.2015, p. 73–117) https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=celex%3A32015L0849. 

6 

 
 
 
 
 
 
 
                                                           
Difficulties in opening a PABF have in particular been found in the following areas. 

1)  Lack of specific identity documents:  difficulties in opening  a PABF due to a lack of 
specific  identity  documents  have  been  identified  in  several  reports 14  and  have  also 
been  the  subject  of  complaints  from  the  general  public  to  the  Commission.  The 
verification  of  the  customer’s  identity  required  by  the  AML/CFT  directives  is 
generally done on the basis of identity documents. A requirement to possess a standard 
identification document issued by the Member State may create particular difficulties 
not  only  for  asylum  seekers  and  refugees,  but  also  (depending  on  the  specific 
requirement) for nationals of other Member States. This issue has already been partly 
addressed in the EBA opinion on the application of customer due diligence measures 
to customers who are asylum seekers from higher-risk non-EU countries or territories 
and  in  the  statement  on  ‘financial  inclusion  in  the  context  of  the  war  in  Ukraine’ 
released  by  the  EBA  on  April  2022.15  In  addition,  homeless  people  sometimes  face 
difficulties in opening a payment account (e.g. when asked to provide an address).  

2)  Cross-border  access  to  payment  accounts:  difficulties  in  opening  a  PABF  in  another 
Member State (including online) have also been reported in the Deloitte Study 1 and 
have been the subject of complaints by the general public to the Commission. These 
can  have  different  causes.  For  example,  such  difficulties  can  be  due  to  a  lack  of 
specific documents or to the need to demonstrate a genuine interest, but they may also 
be  linked  to  AML/CFT  reasons  given  that  opening  a  payment  account  in  another 
Member State may be considered as an unusual circumstance that entails a potentially 
higher risk in the AML/CFT risk assessment 16.  

3)  De-risking practices on AML-grounds: difficulties in opening a PABF have also been 
encountered due to de-risking practices by credit institutions (i.e. when they decide not 
to open (or to close) payment accounts with specific categories of customers because 
they  have  a  higher  money  laundering  and  terrorist  financing  risk).  As  set  out  in  the 
EBA  opinion  on  ‘de-risking’ 17,  de-risking  may  particularly  concern  consumers  with 
links  to  specific  (high  risk)  non-EU  countries  and  politically  exposed  persons.  The 
Commission has also received complaints in this respect. 

4)  De-risking practices due to the US Foreign Account Tax Compliance Act (FATCA): 
difficulties have also been encountered by consumers with double EU/US nationality, 
who  have  filed  petitions  with  the  European  Parliament  and  complained  to  the 
Commission. As the EBA stated in its opinion on de-risking, some credit institutions 
may  have  decided  not  to  provide  payment  accounts  to  US  nationals  in  view  of  the 
obligations and possible sanctions under FATCA. 

14 The  Deloitte  Study  1,  EBA  opinion  on  asylum  seekers,  EBA  consumer  trend  report  2021  EBA  Consumer 
Trend Report (europa.eu). 
15 EBA-Op-2016-07 (Opinion on Customer Due Diligence on Asylum Seekers).pdf (europa.eu); and 
EBA calls on financial institutions and supervisors to provide access to the EU’s financial system | European 
Banking Authority (europa.eu). 
16 See Annex III of Directive (EU) 2015/849 of the European Parliament and of the Council of 20 May 2015 on 
the prevention of the use of the financial system for the purposes of money laundering or terrorist financing. This 
annex  contains  a  non-exhaustive  list  of  factors  and  types  of  evidence  of  potentially  higher  risk  referred  to  in 
Article 18(3) of that directive. 
17 EBA Opinion and annexed report on de-risking.pdf (europa.eu). 

7 

 
 
 
                                                           
The  EBA  has  already  provided  some  guidance  which  may  help  to  address  unwanted  de-
risking 18.  The  EBA  has  in  particular  clarified  that  the  application  of  a  risk-based  approach 
does not require firms to refuse or terminate business relationships with entire categories of 
customers  that  are  considered  to  present  a  higher  money  laundering  and  terrorist  financing 
risk.  Some  Member  States’  competent  authorities  have  therefore  included  this  in  their  own 
guidance.  

To  mitigate  the  risk  of  de-risking  on  AML-grounds,  the  Commission  has  proposed  specific 
provisions  in  the  legislative  package  on  AML/CFT  that  it  presented  in  July  2021  19.  In 
particular, to enable supervisory authorities to assess whether institutions have appropriately 
calibrated  their  customer  due  diligence  practices,  the  proposal  for  an  AML  regulation 20 
includes a requirement for institutions that decide not to enter into a business relationship with 
a  prospective  customer  to  keep  records  of  the  grounds  for  such  a  decision.  In  addition,  the 
proposal  for  a  sixth  AML  directive  21  includes  a  requirement  for  AML  supervisors  to 
cooperate with supervisors in charge of implementing the Payment Services Directive 22 and 
the PAD. 

Difficulties  in  enforcing  the  right  to  a  PABF  may  also  result  from  the  fact,  that  despite  the 
general  obligation  in  Article 16(7)  of  the  PAD  to  immediately  inform  the  consumer  of  the 
refusal  and  of  the  specific  reason  for  that  refusal,  this  often  does  not  happen  due  to  the 
‘tipping off’ prohibition in AML rules which derogates from that general obligation.  

Other derogations provided for in the PAD include the option to require consumers who wish 
to open a PABF to show a genuine interest in doing so (Article 16(2)). Only a few Member 
States  23  have  exercised  this  option.  By  contrast,  many  Member  States  have  exercised  the 
option  provided  in  Article 16(5)  to  permit  credit  institutions  to  refuse  an  application  for  a 
PABF if a consumer already holds a payment account with a credit institution located in their 
territory.  

In addition, several Member States have exercised the option to identify limited and specific 
additional cases where applications can or should be rejected – provided that these exceptions 
are intended to facilitate access to a PABF free of charge under the mechanism of Article 25 
of the PAD or to avoid abuses by consumers (Article 16(6) of the PAD). For instance, some 
Member  States  have  set  criteria  requiring  applicants  to  provide  evidence  that  they  have  not 
committed  fraud  or  other  criminal  offences,  or  they  have  established  a  national  security 
exception. The Article 19(3) option to identify additional limited and specific cases where the 
credit institution may unilaterally terminate a framework contract for a PABF has been used 
by  many  Member  States  for  similar  (and  other)  cases  (e.g.  for  certain  deliberate  criminal 
offences or for commercial activities).  

18 Final Report on Guidelines on revised ML TF Risk Factors.pdf (europa.eu) and EBA Opinion and annexed 
report on de-risking.pdf (europa.eu). 
19 https://ec.europa.eu/info/business-economy-euro/banking-and-finance/financial-supervision-and-risk-
management/anti-money-laundering-and-countering-financing-terrorism_en. 
20COM(2021) 420 final https://eur-lex.europa.eu/resource.html?uri=cellar:0a4db7d6-eace-11eb-93a8-
01aa75ed71a1.0001.02/DOC_1&format=PDF.  
21 COM(2021) 423 final https://eur-lex.europa.eu/resource.html?uri=cellar:05758242-ead6-11eb-93a8-
01aa75ed71a1.0001.02/DOC_1&format=PDF.  
22 Directive (EU) 2015/2366 of the European Parliament and of the Council of 25 November 2015 on payment 
services in the internal market, amending Directives 2002/65/EC, 2009/110/EC and 2013/36/EU and Regulation 
(EU) No 1093/2010, and repealing Directive 2007/64/EC (OJ L 337, 23.12.2015, p. 35). 
23 Five Member States have used this option (see page 72 of Deloitte Study 1). 

8 

 
 
                                                           
  The average annual fees levied for PABFs 
Article 18(1)  of  the  PAD  requires  the  Member  States  to  ensure  that  credit  institutions  offer 
PABFs  ‘free  of  charge  or  for  a  reasonable  fee’.  Member  States  have  implemented  this  in 
different ways. Some Member States 24 have decided that the PABF must be provided free or 
have placed clear limits on the fee or set precise parameters for its calculation. Other Member 
States require that the accounts must be offered free of charge or for a reasonable fee, but do 
not set any further criteria (beyond the Article 18(3) criteria as to what could be considered as 
‘reasonable’).  

The level of fees for PABFs in the different Member States diverges considerably. 25. There is 
also sometimes a big gap between the cheapest and the most expensive offers even within the 
same  Member  State.  Compared  to  the  fees  for  standard  payment  accounts  26,  PABFs  may 
generally be cheaper but not by very much.  

Sector  organisations  and  some  of  the  consumer  organisations  27  in  the  Deloitte  Study  1 
nevertheless indicated that PABFs would generally be affordable for everyone. 

  Application in practice/uptake of the PABF  
As  the  Article 27  report  shows,  for  the  period  2016-2021,  PABFs  have  been  taken  up  to  a 
considerable extent in some Member States.  For instance, there has been a significant uptake 
in some of the Member States  28 that previously had a higher percentage of their population 
without  a  payment  account.  Nevertheless,  uptake  was  rather  low  in  some  others  29.  In 
addition, the latest Global Findex Database from 2021 30 has shown that the share of banked 
population (aged 15 or more) has increased in most Member States from 2017 to 2021 – and 
that some of these reached 100% in 2021. 

A number of different reasons may explain the relatively low number of PABFs. Firstly, the 
percentage of people with a payment account was already very high in many Member States 
when  the  PAD  was  adopted.  Secondly,  some  Member  States  already  had  similar  tools  in 
place.  Thirdly,  given  that  standard  accounts  (including  free  online  accounts)  are  highly 

24  Nine  Member  States  (see  for  details  Deloitte  Study  1,  page  35,  Table  5).  See  also  the  EBA  Report  on  the 
thematic  review  on  the  transparency  and  level  of  fees  and  charges  for  retail  banking  products  published  in 
December 2022 (Report on the thematic review on fees and charges.pdf (europa.eu)).  
25 See  page  34  of  the  Deloitte  Study  1  for  details  of  the  fee  levels  for  PABFs  offered  in  the  selected  Member 
States. These show variations between zero and more than EUR 90 a year.  
26 According to the Deloitte Study 1, the standard fixed fees for payment accounts (to which variable fees may 
need to be added) may be relatively high in some Member States (as much as EUR 160 a year), but they may be 
relatively low (below EUR 20 a year) in others. However, in several Member States, standard accounts with zero 
fixed fees are offered by at least one of the main credit institutions. Digital standard accounts are generally free 
of  charge.  Moreover,  in  some  Member  States,  there  may  also  be  reduced  fees  for  specific  accounts  (e.g.  for 
young or elderly people). The fee levels of different banks within some Member States also vary considerably. 
Despite new entrants into the market, the fees have generally not decreased in recent years.  See page 32 of the 
Deloitte  Study  1  for  more  details  on  the  ‘fee  levels  for  standard  payment  accounts  offered  in  the  selected 
Member States’. 
27 23% of consumer organisations disagreed that everyone could afford to open and use a PABF (see for details 
Deloitte Study 1, Annex D, Figure 14). 
28  For example, Czechia, Cyprus, Greece, Lithuania. See for more details  Table 4: Total number of PABF that 
have been opened each year of Article 27 report. 
29 For example, Bulgaria, Croatia, Latvia, Poland and Romania.  See for more details Table 4: Total number of 
PABF that have been opened each year of Article 27 report.  
No information on the characteristics of consumers who have opened PABF is available in most Member States. 
30 https://www.worldbank.org/en/publication/globalfindex.  

9 

 
 
 
 
 
 
                                                           
accessible,  PABFs  may  not  be  relevant  for  consumers  who  have  access  to  those  accounts. 
Other  reasons  for  a  low  uptake  could  be  a  lack  of  consumer  awareness.  The  necessary 
information  is  available  to  consumers  through  different  channels  such  as  websites  or 
awareness  campaigns,  but  consumer  organisations  consider  that  the  level  of  consumers’ 
awareness of their right to a PABF remains rather low and that many banks do not proactively 
offer the PABF to consumers. In some cases, the cost of a PABF may also limit the uptake. 
As the Global Findex Database has indicated, other reasons for not having a payment account 
given by consumers without a payment account in those Member States that have a lower rate 
of banked people may be insufficient funds, lack of trust in financial institutions or the fact 
that financial institutions are located too far away.  

By  contrast,  this  low  uptake  does  not  seem  to  be  due  to  an  insufficient  offer  of  PABFs 
themselves. PABFs are offered by all or a large number of credit institutions in the individual 
Member  States  and,  according  to  the  Deloitte  Study  1,  sectoral  and  consumer  organisations 
broadly agree that consumers have sufficient access to PABFs. Nor does the low uptake seem 
to be primarily caused by refusals by credit institutions to provide PABFs – as the Article 27 
report  sets  out,  the  number  of  applications  that  have  been  rejected  in  individual  Member 
States seems generally low 31, albeit with some exceptions.  

The  PAD’s  purpose  is  not  necessarily  to  achieve  a  high  uptake  of  PABFs,  but  rather  to 
increase financial inclusion and ensure that all consumers have access to a PABF. Given the 
general  availability  of  PABFs,  this  objective  seems  to  have  been  generally  achieved.  In 
addition, as the latest 2021 Global Findex Database shows, the percentage of the population 
with a payment account has increased in the Member States to 95% on average – and close to 
100% in some Member States.  

Difficulties  may  nevertheless  exist  in  the  specific  cases  outlined  above.  The  purpose  of  the 
AML/CFT  legislative  package  is  to  mitigate  the  risk  of  de-risking.  The  EBA  has  provided 
additional guidance on the interaction between PAD and AML rules 32.  

3.3.  List of services 
Article 17(1) requires the Member States to ensure that a PABF includes a number of services 
(including cash withdrawals, credit transfer, direct debits and payment transactions through a 
payment  card)  to  the  extent  that  they  are  already  offered  to  consumers  holding  standard 
payment accounts. The PABF covers all the services set out in Article 17(1) in most Member 
States.  However,  some  of  the  services  included  in  Article  17(1)  (standing  orders  and  direct 
debits)  were  not  offered  as  part  of  the  PABF  in  a  few  Member  States  33,  because  these 
services were not offered as part of a standard account in those Member States. In some cases, 
credit institutions provide additional services for PABFs (including overdraft facilities, credit 
cards and instant payments), even though this is not required by law.  

Requiring Member States to oblige credit institutions to provide additional features of PABF 
would  need  to  be  justified  for  financial  inclusion  reasons.  This  also  needs  to  be  carefully 
weighed against  the  additional  cost  for  credit institutions  of providing a  PABF  because this 
could  in  turn  increase  the  cost  of  a  PABF  and  thus  impair  financial  inclusion.  Instant 

31 See  for  more details  Table 5: Number and proportion of applications for a  PABF  that  have been refused of 
Article 27 report. 
32 Guidelines on MLTF risk management and access to financial services.pdf (europa.eu) 
33 In three Member States (see for more details Deloitte Study 1, page 76). 

10 

 
 
 
 
 
 
 
                                                           
payments  could  become  a  PABF  feature  in  the  future,  but  –  although  instant  payments  are 
becoming increasingly used – they are not yet standard 34. Another possible additional feature 
could  relate to  ensuring  access  to  cash.  Article 17(1) already requires that  the PABF  should 
include cash withdrawals at the counter or at automated teller machines as a service, but the 
reduction  in  the  number  of  branches  and  ATMs  may  (for  example,  in  some  remote  areas) 
hamper  financial  inclusion  in  general  (and  not  just  PABFs).  As  the  retail  payment 
strategy sets out 35, the Commission shares the concerns that there is a risk that the increasing 
service digitalisation may leave those without access to digital services  even more excluded 
than they are today. The issue of access to and acceptance of cash  was assessed in different 
fora (at the Commission level in the Euro Legal Tender Expert Group (ELTEG) 36 and at the 
Euro Retail Payments Board). Following the report that the ELTEG adopted on 6 July 2022, 
the  Commission  is  assessing  possible  ways  to  ensure  that  euro  cash  is  available  and 
accepted37.  

Consumers and sector organisations both seem to believe that consumers are satisfied with the 
services currently on offer in accordance with national requirements 38. Many Member States 
also do not seem to see a need to amend the PAD.  

4.  SWITCHING OF PAYMENT ACCOUNTS 

A  switching  service  based  on  the  European  Banking  Industry  Committee’s  common 
principles for bank accounts switching 39 already existed in several Member States before the 
PAD  entered  into  force,  but  Article 10  introduced  a  requirement  for  all  Member  States  to 
ensure that a mandatory switching service is in place 40. According to the Deloitte Study 1, the 
PAD  has  thus  enabled  all  consumers  in  the  EU  to  easily  switch  accounts  domestically  and 
often  for  free.  Consumers  who  had  used  the  process  considered  it  to  be  satisfactory.  The 

34  This  could  however  change  if  the  legislative  proposal  on  instant  payments  (Proposal  for  a  Regulation 
amending  Regulations  (EU)  No  260/2012  and  (EU)  2021/1230  as  regards  instant  credit  transfers  in  euro 
(europa.eu)) is adopted.   
35 Communication from the Commission to the European Parliament, the Council, the European Economic and 
Social  Committee  and  the  Committee  of  the  Regions  on  a  Retail  Payments  Strategy  for  the  EU 
(COM(2020) 592 final).  
https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52020DC0592&rid=2. 
36 ELTEG is a Commission expert group of Member States’ experts and the European Central Bank (ECB). Its 
main purpose is to discuss euro cash acceptance and availability. The ELTEG’s latest report of July 2022 stated 
that Member States should monitor ATM networks and additional cash access points at bank branches to ensure 
that  they  provide  sufficient  coverage,  especially  when  such  facilities  are  closed.  It  also  stated  that  policy 
measures should be taken to ensure that euro cash is available. 
37 See the Commission initiative on the scope and effects of legal tender of euro banknotes and coins of the 2023 
Commission work programme (2023 Commission work programme – key documents (europa.eu)). 
38 83% of sector organisations and 77% of consumer organisations agreed that consumers are satisfied with the 
services  included  in  a  PABF  (The  rest  of  the  respondents'  answers  were  “don't  know”).  See  for  more  details 
Deloitte Study 1, page 77). 
39 The  EBIC  common  principles  for  bank  accounts  switching.  The  common  principles  for  bank  account 
switching were implemented by the end of 2009. EBIC stated that they have been implemented by all Member 
States.  However, 
incomplete  and  inadequate.  See  for  more  details  https://eur-
lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52013SC0127&from=EN.   
40  According  to  Deloitte  Study  1,  ten  Member  States  only  had  to  make  minor  changes  to  their  existing 
framework, two Member States more substantial changes and, in three Member States a new switching service 
was introduced (see for more details page 53). 

implementation  was 

11 

 
 
 
 
 
 
                                                           
shortcomings  reported  by  consumer  organisations  relate  to  technical  issues  in  applying  the 
process in individual cases, but not to the process itself 41.  

As  the  Article 27  report  shows,  the  number  of  yearly  switches  varies  considerably  between 
the  different  Member  States.  There  is  a  considerable  number  of  switches  in  some  Member 
States  42  and  a  growing  trend  in  some  of  these,  but  very  low  switching  in  other  Member 
States43. 

A  number  of  factors  may  be  affecting  the  level  of  switching 44.  For  instance,  the  switching 
service applies to payment accounts but not to other financial products (e.g. mortgage loans 
and investments) to which the payment account may be linked.  In addition, consumers may 
have only  a limited awareness  of the service and may not  always be informed about  it – or 
even discouraged from using it. Other possible reasons include insufficient financial literacy 
and  the  assumption  that  switching  would  only  lead  to  limited  savings;  a  desire  not  to  lose 
one’s payment account number; and the risk that payments may go astray. 45 

However,  the  aim  of  the  PAD’s  switching  provisions  was  not  necessarily  to  increase  the 
number of switches – but rather to make it easier to switch in order to increase competition. 
Given the general availability of a (well-functioning) switching service, the aim of making it 
easier to switch seems to have been achieved. It could nevertheless be useful to take additional 
measures,  in  particular  to  raise  consumers’  awareness  of  their  right  to  switch  a  payment 
account.  

Unlike  for  domestic  situations,  there  is  currently  no  switching  service  for  cases  involving 
payment service providers from different Member States. Instead, Article 11 only obliges the 
transferring  payment  service  provider  to  provide  assistance  (e.g.  provide  information  and 
transfer funds) to consumers when they state their intention to open a payment account with a 
payment service provider located in another Member State. As shown by the Deloitte Study 1, 
the  level  of  interest  in  cross-border  access  to  a  payment  account  of  consumers  is  low, 
although  it  may  be  increasing  due  to  the  spread  of  neo-banks  46.  Some  factors  that  may  be 
affecting the level of interest could be a preference to be physically close to a bank, language 
barriers and the fact that domestic accounts can be used throughout the EU. 

41 These technical issues  which happened in individual cases include a former account being closed before the 
new  account  becomes  operational;  new  debit/credit  cards  delivered  after  deactivation  of  previous  cards;  and 
transactions  made  with  debit  cards  in  shops  and/or  direct  debits  charged  only  weeks  after  the  transaction  –
resulting in debt collections. 
42  For  example,  Denmark  or  France.  See  for  more  details  Table  1:  Number  of  yearly  switches  of  Article  27 
report. 
43 For example, Bulgaria, Greece, Cyprus, Malta, Portugal or Romania. See for more details Table 1: Number of 
yearly switches of Article 27 report. The 2022 Eurobarometer survey on retail financial services and products has 
shown higher switching rates. https://europa.eu/eurobarometer/surveys/detail/2666.  
44 For a behavioural perspective on the reasons for not switching, see the study Applying behavioural insight to 
encourage consumer switching of financial products - Publications Office of the EU (europa.eu). 
45 The  special  Eurobarometer  survey  of  2016  on  switching  of  financial  products  and  services  more  generally 
reported  as  the  two  main  reasons  for  not  switching  the  fact  that  consumers  are  satisfied  with  their  current 
provider and the fact that they have never considered switching (Financial Products and Services - July 2016 - - 
Eurobarometer survey (europa.eu)). 
46 See page 120 of Deloitte Study 1 for more information on neo-banks. 

12 

 
 
 
 
 
 
 
 
                                                           
5.  ASSESSMENT OF POSSIBLE FURTHER MEASURES ON SWITCHING   

5.1.  Feasibility of extending the switching service in  Article 10 to cross-border 
switching  
Extending the switching service to cross-border cases would make it easier to switch payment 
accounts to other Member States and as easy as switching within one and the same Member 
State.  

There are several different ways to extend the current switching service for cases within one 
Member  State  to  switching  cases  between  two  Member  States  (e.g.  interconnecting  the 
different  switching  services  at  national  level  or  creating  a  standardised  EU-wide  switching 
service which would replace the existing systems for domestic switching). This second option 
would  imply  a  leaner  process  but  would  involve  a  more  radical  IT  transformation  for  the 
different stakeholders 47.  

Both options would be technically feasible. However, based on the estimated switching rates, 
the  expected  cost  (one-off  cost  plus  recurrent  cost)  would  largely  outweigh  the  expected 
benefits:  the  one-off  costs  of  both  options  have  been  estimated  at  around  EUR 840 million, 
and the recurrent costs at around EUR 158 million a year 48. However, the (recurrent) benefits 
(mainly for consumers 49) would be only around EUR 41 million a year 50. In addition, given 
the  (expected)  low  level  of  cross-border  switching,  consumer  organisations  do  not  see  the 
extension  of  the  switching  service  to  cross-border  cases  as  a  priority  (whereas  credit 
institutions  see  no  advantage  and  point  to  language  barriers,  physical  distance  and  other 
obstacles).  

5.2.  Feasibility of a framework for automated redirection of payments  
A framework for an automated redirection of payments would ensure that, for a certain period 
of  time  after  a  consumer  has  switched  payment  accounts,  payments  to  the  previous  (‘old’) 
account  would  be  redirected  to  their  new  account.  This  would  reduce  possible  concerns  by 
providing  additional  reassurance  that  the  incoming  payments  would  arrive  in  the  right 
account.  This  would  also  make  it  easier  to  switch  and  thus  increase  competition.  Such  an 
automated redirection service already exists in the Netherlands as an additional feature of its 
domestic switching service. A framework for an automated redirection of payments could be 
set up domestically within individual Member States or within the EU as a whole. Setting up 
such a framework at EU level would first require the  setting up of a cross-border switching 

47  The  different  stakeholders  that  were  considered  for  the  study  were  the  following:  consumers,  competent 
authorities  (national  competent  authorities  or  a  competent  authority  at  EU  level),  creditors/debtors  (all  third 
parties  with  whom consumers  may  have  recurrent payments, direct debits or standing orders) PSPs and others 
(either PSPs acting collectively, national competent authorities, or EU competent authorities when it is not clear 
which stakeholder would be bearing the cost). See for details Deloitte Study 2, page 76. 
48 These figures relate only to consumers for all options (5.1, 5.2 and 5.3). PSPs would bear most of the one-off 
cost (EUR 835 million) and most of recurrent costs (EUR 150 million). See page 84 of the Deloitte Study 2 for 
more details. 
49  For  the  calculation  of  recurrent  benefits  for  consumers,  the  Deloitte  Study  2  has  considered  benefits  due  to 
spending less time to carry out a switch, benefits linked to not having to deal with an increased number of failed 
payments and benefits linked to potential savings in account fees for (additional) consumers who switch. See for 
details Deloitte Study 2, page 77. 
50 A cross-border switching rate of more than 4.2% (as opposed to an estimated cross-border switching rate of 
0.2%) would be required in order to break even after 20 years. See page 97 of the Deloitte Study 2 for details. 
The  options  (5.1  and  5.3)  would  not  be  considered  efficient  even  on  the  basis  of  the  higher  switching  rates 
indicated by the 2022 Eurobarometer survey on retail financial services and products.  

13 

 
 
 
 
                                                           
service.  Such  a  framework  could  be  set  up  in  a  number  of  different  ways  (e.g.  a  system  in 
which new account details would be included in the error messages sent to banks attempting 
to  make  a  transfer  to  a  closed  account;  a  system  in  which  redirection  tables  would  be 
integrated in the routing systems of banks; and setting up a separate central clearing engine to 
manage the switching information).  

However, based on estimated switching rates, the expected costs (one-off costs plus recurrent 
costs) would largely outweigh the expected benefits. The one-off costs of any of the options 
have been estimated at between EUR 1 and 5 billion. The annual recurrent costs of the options 
range from EUR 228 million to EUR 782 million for automated redirection at domestic level, 
and from EUR 461 million to EUR 1 billion for automated redirection at EU level combined 
with a switching service  51. However, the (annual recurrent) benefits (mainly for consumers) 
would  only  be  around  EUR 80 million  for  automated  redirection  at  domestic  level  and 
EUR 154 million for automated redirection at EU level 52.  

5.3.  Assessment  of  the  costs  and  benefits  of  implementing  full  EU-wide 
portability of payment account numbers 
Full  EU-wide  account  number portability  would  mean that it would be  possible  to  keep the 
same payment account number when switching payment accounts within the EU. Consumers 
would  no  longer  need  to  notify  creditors  and/or  debtors  with  whom  they  have  recurrent 
transactions of their new payment account number, and their creditors/debtors would not need 
to  update  their  accounting  systems.  Keeping  the  same  account  number  would  provide 
consumers with the assurance that all incoming payments would arrive in the right  payment 
account.  This  would  reduce  possible  concerns  and  make  switching  easier  not  only 
domestically but also across borders. This would promote competition.  

Payment account number portability could be organised in different ways. One option would 
be the portability of an existing IBAN that would be connected to a new IBAN in the back-
end  (the  consumer  would  not  necessarily  know  this).  An  alternative  option  would  be  the 
creation  of  an  alias  that  could  be  linked  to  an  existing  IBAN  and  communicated  to 
debtors/creditors. When switching accounts, the alias (i.e. the front-end) could be linked to a 
new IBAN in the back-end (again the consumer would not necessarily know this). A third and 
more fundamental option would be to replace all existing IBANs with new EU IBANs (new 
portable account number). This is the only option where the account number would be truly 
portable and would only require the BIC as a back-end identifier to enable banks to identify 
where the account is located. 

Based  on  estimated  switching  rates,  the  expected  costs  (one-off  costs  plus  recurrent  costs) 
would  largely  outweigh  the  expected  benefits.  The  one-off  costs  have  been  estimated  at 
between  EUR 7 and  22 billion  53  and  the  recurrent  costs  for  these  options  at  around 

51 PSPs would bear most of the one-off and recurrent costs. Competent authorities would only bear one-off cost 
(between EUR 2 and 12 million) and creditors/debtors would only bear recurrent cost (between EUR 20 and 40 
million).   
52 According to the Deloitte Study 2, it would not be possible to break even under these options  – even with a 
high level of switching. 
53 The one-off costs would be around EUR 22 billion for the option of a new portable account number.  

14 

 
 
 
 
                                                           
EUR 1 billion a year 54. On the other hand, the (recurrent) benefits (mainly for consumers and 
creditors/debtors) would only be between EUR 151 million and EUR 242 million a year 55.  

As shown by Deloitte Study 1, sectoral organisations do not see account number portability as 
a major game-changer for switching. Consumer organisations have mixed views 56 but do not 
see the creation of a cross-border switching service as a priority.  

On the basis of the result of the study, it is clear that these possible additional measures could 
make it even easier to switch payment accounts within the EU. However, given that the cost 
would  largely  outweigh  their  expected  benefits  at  present,  they  may  not  seem  justifiable  at 
this stage.  

6.  EFFECTIVENESS  OF  EXISTING  MEASURES  AND  THE  NEED  FOR 
ADDITIONAL  MEASURES  TO  INCREASE  FINANCIAL  INCLUSION  AND  TO 
ASSIST VULNERABLE PEOPLE IN RELATION TO OVER-INDEBTEDNESS 

Access  to  a  payment  account  is  essential  if  people  are  to  participate  in  the  economy  and 
society. It is a vital tool for financial inclusion. In the EU, the percentage of consumers who 
have  a  payment  account  is  generally  (very)  high.  According  to  the  latest  Global  Findex 
Database from 2021, an average of 95% of citizens in the EU aged 15 or more have at least 
one payment account 57. This proportion has risen in recent  years (by four percentage points 
since  2017).  This  may  be  due  to  different  factors:  digital  finance,  the  arrival  of  cost-free 
digital accounts, and the fact that the PAD provides the right to a basic bank account. 

However,  the  2021  Global  Findex  Database  shows  considerable  differences  between  the 
Member  States.  While  more  than  95%  of  the  population  (aged  15  or  more)  has  a  payment 
account in many Member States, this proportion is considerably lower in some other Member 
States 58.  The  Global  Findex  Database  also  underlined  differences  between  types  of 
consumers, in particular vulnerable persons  59. The Deloitte Study 1  also showed that sector 
and consumer organisations consider that being homeless and being an immigrant entails the 
highest  risk  of  not  having  a  payment  account.  PAD  already  provides  for  a  legal  right  to  a 
PABF (including for vulnerable people) for a reasonable fee. The question of whether or not 
the  PAD  will  need  to  be  amended  in  order  to  further  strengthen  financial  inclusion,  for 
instance in relation to the fees of a PABF, will be assessed in more detail in line with better 
regulation standards. Additional non-legislative measures such as the EBA guidelines on the 

54 PSPs would bear most of the one-off and recurrent costs unless this option would be implemented by replacing 
of all current IBANs by EU IBANs. In this case, creditors/debtors would bear more than half of one-off costs 
(EUR 12 billion). 
55 According to the Deloitte Study 2, break-even after 20 years would require national switching rates of 8% (as 
opposed to an estimated actual switching rate of 1%) and cross-border switching rates of 2.4% (as opposed to an 
estimated actual switching rate of 0.3%). 
56  42%  of  consumer  organisations  answered  “no”  to  the  question  of  whether  EU  wide  portability  of  payment 
accounts  would  be  a  major  game  changer  for  switching,  notably  cross-border.  See  for  more  details  Deloitte 
Study 1, page 59. 
57 The  figures  shown  by  the  2022  Eurobarometer  survey  on  retail  financial  services  and  products  are  slightly 
lower than those of the Global Findex Database 2021. 
58 For example, 69 % in Romania, 84% in Bulgaria and 88% in Hungary.  
59 While being vulnerable (e.g. being unemployed, having a low level of education or income) has little effect on 
whether or not someone has a payment account in those Member States where the percentage of people with a 
payment account is very high, such vulnerable people are less likely to have a payment account in those Member 
States with a lower the percentage of people with a payment account. 

15 

 
 
 
                                                           
interaction  between  the  AMLD  and  the  PAD,  and  awareness-raising  measures  in  some 
Member States could be useful. 

Digitalisation may create additional barriers to financial inclusion. Digitalisation may in some 
ways help increase financial inclusion (e.g. through online access to banking services at any 
time), but increased digitalisation can also involve reduced physical access (to branches and 
ATMs) and may create difficulties for consumers who are either not digitally literate or have 
no access to digital devices. In fact, the reduction in the number of ATMs and branch offices 
in recent  years has reduced the availability of basic payment services 60. The Commission is 
working to address these issues in several ways. In particular, the Commission is working to 
foster financial literacy (within the limits of its Treaty competence). Together with the OECD, 
the  Commission  has  developed  a  financial  competence  framework  for  adults 61,  which 
specifically covers digital financial literacy. The Commission and the OECD are now working 
on a similar competence framework for youth. As set out in the capital markets union action 
plan 62,  the  Commission  is  also  assessing  the  possibility  of  introducing  a  requirement  for 
Member  States  to  promote  learning  measures  supporting  financial  education.  Moreover,  the 
Commission  stands  ready  to  continue  to  support  Member  States  in  the  area  of  financial 
literacy  and  inclusion  through  the  Technical  Support  Instrument.  63  As  of  today,  it  has 
delivered some 20 technical support projects ranging from broader topics such as support for 
the  implementation  of  national  financial  literacy  strategies  to  more  focused  areas  covering 
ageing population, retail investors or digital literacy. 64 As set out above (point 3.3), work on 
access to and acceptance of cash is being carried out.  

The Commission has recently launched a study on EU consumers’ over-indebtedness and its 
implications. The study will give an overview of the over-indebtedness of EU households and 
consumers,  taking  into  consideration  the  impact  of  the  COVID-19  on  households’  over-
indebtedness. 

7.  EXAMPLES  OF  BEST  PRACTICES  AMONG  MEMBER  STATES  FOR 
REDUCING  CONSUMER  EXCLUSION  FROM  ACCESS  TO  PAYMENT 
SERVICES.  

Member  States  have  taken  a  number  of  different  measures  –  to  transpose  the  PAD  and  to 
avoid  or  limit  financial  exclusion  from  access  to  payment  services  –  that  can  serve  as  best 
practices.  

To  facilitate  access  to  a  PABF  and  avoid  exclusion,  at  least  one  Member  State  has  a 
mechanism to designate a specific credit institution to provide a PABF to a consumer whose 
applications  for a PABF have been rejected. Such a mechanism  can make it much easier to 
gain access to a PABF in practice, particularly for consumers who are vulnerable or de-risked 
by  some  banks.  Few  Member  States  have  issued  guidance  to  credit  institutions  on  the 
interaction of the PAD and AML/CFT requirements for cases where customers do not have a 

60 See also the EBA Consumer Trend Report (europa.eu). 
61 The Commission and OECD-INFE publish a joint framework for adults to improve individuals’ financial 
skills (europa.eu).  
62 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=COM:2020:590:FIN.  
63 Regulation (EU) 2021/240 of the European Parliament and of the Council of 10 February 2021 establishing a 
Technical Support Instrument OJ L 57, 18.2.2021, p. 1–16. 
64 Example of technical support project supporting financial literacy in Member States: Protecting consumers and 
enhancing financial literacy (europa.eu). 

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fixed address  or standard documentation. To address  the identity documents issue, a system 
was  established  in  one  Member  State  so  that  social  workers  can  vouch  for  the  identity  of  a 
homeless person seeking to open a payment account.  

To limit the cost of a PABF, some Member States require PABFs to be provided cost-free to 
everyone  or  just  to  particularly  vulnerable  groups.  In  other  cases,  Member  States  have  set 
clear and low limits for the fees – for example, in absolute terms or in relative terms (e.g. in 
relation  to  other  payment  accounts).  Other  Member  States  have  set  up  different  pricing 
schemes to grant more advantageous conditions to vulnerable consumers.  

To  increase  awareness,  several  Member  States  have  taken  action  to  inform  consumers  and 
raise  their  awareness  of  PABFs,  particularly  through  leaflets,  guides  and  information  on 
websites. Member States have also developed many initiatives to improve financial inclusion 
through different financial literacy programmes 65.  

8.  CONCLUSION  

The objectives of the PAD are to (1) create transparency and ensure comparability of payment 
account fees, (2) ensure that consumers have access to payment accounts (with basic features) 
and (3) make it easier to switch payment accounts.  

In general, the PAD has helped to create transparency and comparability of payment account 
fees. It has in particular ensured a minimum level of harmonisation, notably by establishing a 
standardised  terminology  (which  is  partially  uniform  at  EU  level),  common  templates  to 
report on fees linked to payment accounts, a uniform switching process, and an EU-level right 
of access to PABFs. However, some Member States have created an additional layer of new 
legislation  when  transposing  the  PAD  –  rather  than  replacing  existing  legislation  –  and  this 
makes  the  national  and  EU  regulatory  framework  more  fragmented.  The  most  important 
unintended  consequence  of  this  has  been  the  duplication  of  documents  on  fee  levels  of 
payment  accounts  in  Member  States  where  documents  with  the  same  information  already 
existed.  The  measures  put  forward  by  the  PAD  (particularly  comparison  websites)  can 
improve  transparency  and  consumers’  ability  to  compare  fees.  However,  some  aspects  still 
require improvement, and cross-border transparency and comparison are not yet possible due 
to differences in the terminology used and to language barriers. 

The PAD has also ensured that consumers have access to PABFs which are offered by all or 
many credit institutions in each Member State. The percentage of EU consumers who have a 
payment account is generally (very) high and has risen further since the entry into force of the 
PAD.  PABFs  have  been  taken  up  to  a  considerable  extent  in  some  Member  States.  For 
instance, there has been a significant uptake in some of the Member States that previously had 
a higher percentage of their population without a payment account. Nevertheless, uptake was 
rather  low  in  some  others.  There  may  be  different  reasons  for  a  relatively  low  uptake  (e.g. 
standard  accounts  are  highly  accessible,  free  online  accounts,  a  lack  of  consumers  and  in 
some cases the cost of having a PABF). However, the PAD did not necessarily aim at a high 
uptake of PABF, but rather at enhancing financial inclusion and ensuring that all consumers 
have access to a PABF. Given the general availability of PABFs, this objective seems to have 
been generally  achieved.  Difficulties may  nevertheless  exist in  specific cases.  The EBA has 

65 For an overview of national measures, see Financial education | European Banking Authority (europa.eu). 

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provided  additional  guidance  on  the  interaction  between  PAD  and  anti-money-laundering 
rules. Additional measures could also be useful, in particular to raise consumers’ awareness of 
their right to a PABF.  

The PAD has also enabled all EU consumers to easily switch accounts domestically, often for 
free. As the Article 27 report shows, there are considerable differences between the different 
Member  States  in  the  number  of  yearly  switches.  There  has  been  some  switching  in  some 
Member States (with an increasing trend in several cases), but the level of switching has been 
very low in other Member States. This may be due to a number of different factors, including 
the fact that the switching service only applies to payment accounts (but not to other financial 
products, such as mortgage loans and investments) and limited consumer awareness about the 
switching  service  –  but  also  due  to  satisfaction  with  the  current  provider  and  the  fact  that 
some consumers have never considered switching. However, the aim of the PAD’s switching 
provisions  was  not  necessarily  to  increase  the  number  of  switches,  but  rather  to  increase 
competition by making it easier for consumers to switch payment accounts. Given the general 
availability  of  a  (well-functioning)  switching  service,  the  aim  of  making  it  easier  to  switch 
seems to have been accomplished. Additional measures could be useful, particularly to raise 
consumers’ awareness of their right to switch.  

Additional  measures  could  be  taken  to  make  it  even  easier  to  switch  within  the  EU  in  the 
future  (i.e.  extending  the  switching  service  to  cross-border  cases;  ensuring  automated 
redirection of payments within the same Member State, or to and from another Member State; 
or ensuring full EU-wide portability of payment account numbers). However, given that the 
cost  of  these  measures  would  largely  outweigh  their  expected  benefits  at  present,  they  may 
not seem justifiable at this stage.  

In light of the above, the Commission does not present any legislative proposal together with 
this report. Whether the PAD needs to be amended will need to be considered in further detail 
and  in  line  with  better  regulation  standards  at  a  later  stage  and  taking  into  account,  in 
particular,  the  EBA  Guidelines  on  the  interaction  between  PAD  and  AML  rules.  The 
Commission will continue monitoring the implementation and enforcement of the Directive in 
Member States. 

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