REPORT FROM THE COMMISSION assembling specific payment account related data from Member States as required by Article 27 of the 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, consumer information, disclosure of information, financial services, intra-EU payment, single market

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 12.5.2023  COM(2023) 248 final  REPORT FROM THE COMMISSION assembling specific payment account related data from Member States as required by Article 27 of the 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.  

2. 

INTRODUCTION ..................................................................................................................... 2 

COMPLIANCE BY PAYMENT SERVICE PROVIDERS WITH ARTICLES 4, 5 AND 6 
 ..................................................................................................................................................... 2 

COMPLIANCE BY MEMBER STATES WITH THE REQUIREMENTS TO ENSURE 

3. 
THE EXISTENCE OF COMPARISON WEBSITES PURSUANT TO ARTICLE 7 .................... 5 

NUMBER OF PAYMENT ACCOUNTS THAT HAVE BEEN SWITCHED AND THE 

4. 
PROPORTION OF APPLICATIONS FOR SWITCHING THAT HAVE BEEN REFUSED ...... 5 

NUMBER OF CREDIT INSTITUTIONS OFFERING PAYMENT ACCOUNTS WITH 
5. 
BASIC FEATURES, THE NUMBER OF SUCH ACCOUNTS THAT HAVE BEEN OPENED 
AND THE PROPORTION OF APPLICATIONS FOR PAYMENT ACCOUNTS WITH BASIC 
FEATURES THAT HAVE BEEN REFUSED ................................................................................... 8 

6. 

CONCLUSION ........................................................................................................................ 12 

1 

 
 
 
 
 
 
 
1.  

INTRODUCTION 

The Payment Accounts Directive (the PAD or the Directive)1 entered into force in September 
2014. Member States had until 18 September 2016 to adopt and publish the laws, regulations 
and administrative provisions necessary to comply with the Directive. Under Article 27 of the 
Directive, the Commission is required to prepare a report (for the first time by 18 September 
2018 and every two years) providing the following information: 

1.  compliance by payment service providers with Articles 4, 5 and 6; 
2.  compliance  by  Member  States  with  the  requirements  to  ensure  the  existence  of 

comparison websites pursuant to Article 7; 

3.  the  number  of  payment  accounts  that  have  been  switched  and  the  proportion  of 

applications for switching that have been refused; 

4.  the  number  of  credit  institutions  offering  payment  accounts  with  basic  features,  the 
number of such accounts that have been opened and the proportion of applications for 
payment accounts with basic features that have been refused. 

As  set  out  in  Article 27,  the  report  is  based  on  information  provided  by  Member  States. 
However, there are certain gaps in the data received and reported (e.g. when information was 
not available in a Member State). Also, data collection methodologies and sources may have 
varied  across  Member  States,  which  may  make  comparisons  and  assessment  of  the  data 
difficult.  

This is the first Article 27 report2 which covers the period from 2016 to 2021. In addition to 
this report, the Commission  has simultaneously adopted the report on the application of the 
Directive, as required under Article 28. 

2.  COMPLIANCE  BY  PAYMENT  SERVICE  PROVIDERS  WITH  ARTICLES  4,  5 

AND 6 

Chapter  II  of  the  Directive  lays  down  rules  on  the  comparability  of  fees  connected  with 
payment  accounts.  As  laid  down  in  the  various  recitals,  Chapter  II  pursues  two  aims:  to 
improve and develop the internal market for retail banking while ensuring that consumers are 
able to understand fees so that they can compare offers and make informed decisions. 

The  first  step  towards  achieving  these  two  goals  is  through  defining  the  standardised 
terminology  referred to under Article 3 of the Directive. Through an integrated and step-by-
step approach, Member States are now equipped with a list of the most representative services 
linked to a payment account and subject to a fee. These standardised terms  also serve as the 
basis  for  the  remaining  articles  of  Chapter  II  in  the  sense  that,  in  order  to  comply  with  the 
respective  articles  of  Chapter  II,  payment  service  providers  need  to  use  the  agreed 
standardised terms. 

1  
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). 
2  
This  report  had  to  be  postponed  in  part  to  ensure  that  the  relevant  data  were  available  because  most 
Member  States  were  late  in  transposing  the  Directive.  Moreover,  the  delegated  acts  (implementing  technical 
standards  and  regulatory  technical  standards),  which  are  instrumental  for  implementing  the  transparency 
requirements of the Directive, were delayed and became applicable only in October 2018. 

2 

 
 
 
 
 
                                                           
In  line  with  Article 27  of  the  Directive,  Member  States  have  provided  the  following 
information  on  Articles  4,  5,  and  6  concerning  the  level  of  compliance  by  payment  service 
providers. 

a)  Article 4 (Fee information document and glossary) 
Article 4  of  the  Directive  provides  that,  ‘in  good  time  before  entering  into  a  contract  for  a 
payment  account  with  a  consumer,  payment  service  providers  provide  the  consumer  with  a 
fee  information  document  on  paper  or  another  durable  medium  containing  the  standardised 
terms’ and ‘the corresponding fees for each service’ the provider offers. Article 4, through an 
Implementing Regulation3, also lays down precise rules on the actual presentation of the fee 
information document and obliges payment service providers to make available to consumers 
a glossary of at least the standardised terms and the related definitions. Article 4 also requires 
providers to make available to consumers, at any time, the fee information document and the 
glossary.  This  is  to  be  in  electronic  form  on  their  websites,  and  on  their  premises. 
Additionally, this provision requires providers to make available, on paper or another durable 
medium and free of charge, the fee information document and the glossary, upon a consumer 
request. 

With regard to the level of compliance by payment service providers with the obligation 
to  provide  the  fee  information  document  to  consumers  in  good  time  (Article 4(1)),  the 
general  indication  is  that  providers  are  compliant.  This  emerges  either  from  on-site 
inspections  or  surveys  (BG,  FR,  CY,  LV,  PT,  SI)  or  from  the  fact  that  no  complaints  were 
received, implying that in general providers seem to comply (BE, CZ, DK, DE, EE, FR, HR, 
IT, LT, LU, HU, MT, NL, AT, PL, RO, SK, FI).  

With regard to the level of compliance by payment service providers with the obligation 
to  make  available  to  consumers  a  glossary  of  at  least  the  standardised  terms 
(Article 4(4)), the general indication is that providers are compliant. This emerges either from 
on-site inspections or surveys (BG, FR, CY, LV, PT, SI) or from the fact that no complaints 
were received, implying that in general payment service providers seem to comply (BE, CZ, 
DK, DE, EE, HR, IT, LT, LU, HU, MT, NL, AT, PL, SK, FI). 

With regard to the level of compliance by payment service providers with the requirement 
to make available to consumers (and non-customers) at any time on their website and on 
their  premises  the  fee  information  document  and  glossary  (Article  4(5)),  the  general 
indication is that payment service providers  are compliant. This emerges either from  on-site 
inspections  or  surveys  (BG,  FR,  CY,  LV,  PT,  SI)  or  from  the  fact  that  no  complaints  were 
received, implying that in general payment service providers seem to comply (BE, CZ, DK, 
DE, EE, HR, IT, LT, LU, HU, MT, NL, AT, PL, SK, FI). 

b)  Article 5 (Statement of fees) 
Article 5 of the Directive lays down the obligation related to providing the statement of fees. 
In  line  with  this,  the  Commission  enacted  an  Implementing  Regulation4  that  lays  out  the 
standardised  presentation  format  of  the  statement  of  fees  and  its  common  symbol.  Article 5 

3 
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, 
C/2017/6456 OJ L 6, 11.1.2018, p. 37. 
4 
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, C/2017/6453, OJ L 6, 
11.1.2018, p. 26. 

3 

 
 
                                                           
provides that payment service providers provide the consumer,  at  least  annually and free of 
charge, with a statement of all fees incurred for services linked to a payment account. 

With regard to the level of compliance by payment service providers with the obligation 
to  provide  at  least  annually  and  free  of  charge  a  statement  of  all  fees  incurred 
(Article 5(1)), the general indication is that providers are compliant. This emerges either from 
on-site  inspections  or  surveys  (AT,  SI)  or  from  the  fact  that  no  complaints  were  received, 
implying that in  general  providers seem to comply (BE, BG, CZ, DK, DE, EE, IE, EL, FR, 
HR, IT, CY, LV, LT, LU, HU, MT, NL, PL, SK, FI). 

Most  Member  States  informed  the  Commission  that  no  enforcement  action  based  on 
infringements of Article 5 has  been taken.  A few Member States  (DE,  IE, FR, HU, NL) 
pointed  to  teething  problems  around  the  date  of  implementation.  In  these  cases,  consumer 
protection warnings were issued to the relevant service providers, calling for compliance with 
the provisions of the law without any delay. Ireland explained that, while certain retail credit 
institutions had issues in meeting the 31 October 2019 deadline due to system/IT constraints, 
workarounds  and  system  fixes  were  put  in  place  and  thus  no  enforcement  action  has  been 
taken  to  date.  The  Netherlands  explained  that  it  chose  to  engage  with  the  payment  service 
providers in an informal way (no formal enforcement actions). Portugal issued, in 2019, 227 
specific  orders  to  115  payment  service  providers  for  failure  to  comply  with  Article  5;  the 
irregularities  and  non-compliances  detected  referred  mainly  to  the  rules  applicable  to  the 
submission of the statement of fees and to its template and completion requirements. Czechia 
explained that, in 2019, one of the foreign bank branches failed to provide consumers with the 
statement  of  fees  by  the  end  of  February;  this  was  due  to  technical  difficulties.  In  the 
beginning of July, during the Czech National Bank’s investigation, the statement was sent to 
all clients of that branch. 

c)  Article 6: Information for consumers 
Article 6 of the Directive obliges payment service providers, in their contractual, commercial 
and  marketing  information  to  consumers,  to  use  where  applicable  the  standardised  terms. 
Payment service providers are allowed to use brand names in the fee information document 
and in the statement of fees, provided such brand names are used as a secondary designation 
of those services. 

With regard to the level of compliance by payment service providers with the obligation 
to  use  the  standardised  terms  in  their  contractual,  commercial  and  marketing 
information  to  consumers  (Article 6(1)),  providers  appear  generally  compliant.  This 
emerges  either  from  on-site  inspections  or  surveys  (CY)  or  from  the  absence  of  complaints 
implying (BE, BG, CZ, DK, DE, EE, EL, FR, HR, LV, LT, LU, HU, MT, NL, AT, PL, SI, 
SK, FI). Cyprus  stated that  the outcome of the survey  showed that  only  two banks reported 
that  work  was  still  in  progress,  and  they  expect  to  fully  comply  with  the  requirements  of 
Article 6 by the end of 2022. 

With  regard  to  how  frequent  it  is  that  payment  service  providers  include  their  brand 
name in the fee information document and the statement of fees document,  the  general 
picture is that quite often providers do include the brand name. 

With regard to information on any enforcement action based on infringements of Article 6 
of  the  Directive,  all  Member  States  that  replied  to  this  question  stated  that  no  such 
enforcement  has  taken  place.  France  stated  that  it  came  across  minor  anomalies  (i.e.  use  of 
non-standardised  terms,  diverging  terms  used  for  the  same  service  in  different  documents, 
etc.),  which  can  create  confusion  for  customers.  However,  no  sanctions  have  been  imposed 
due to the fact that these infringements were considered as non-substantial. 

4 

 
 
3.  COMPLIANCE  BY  MEMBER  STATES  WITH  THE  REQUIREMENTS  UNDER 
ARTICLE 7 TO ENSURE THE EXISTENCE OF COMPARISON WEBSITES 

Article 7 of the Directive obliges Member States to ensure that consumers have access, free of 
charge, to at least one website comparing fees charged by payment providers for at least the 
services  found  in  the  national  list  of  the  most  representative  services  linked  to  a  payment 
account and subject to a fee. This Article also provides that the comparison website may be 
operated  either  by  a  private  operator  or  by  a  public  authority,  and  that  it  be  run  in  an 
independent manner. It must also: disclose the owner of the website; set out clear, objective 
criteria upon which the comparison is based; 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. 

As of January 2021, nearly all Member States5 have at least one comparison website up and 
running,  as  required  under  Article 7.  The  vast  majority  of  Member  States  have  tasked  the 
setting up and subsequent updating of the table to a public authority6. 

4.  NUMBER  OF  PAYMENT  ACCOUNTS  THAT  HAVE  BEEN  SWITCHED  AND 
THE  PROPORTION  OF  APPLICATIONS  FOR  SWITCHING  THAT  HAVE 
BEEN REFUSED 

a)  Payment accounts that have been switched 

With  the  aim  to  facilitate  the  switching  of  payment  accounts,  Article  10  of  the  Directive 
obliged  Member  States  to  ensure  that  payment  service  providers  provide  a  clear  and  quick 
switching service within the Member State.   

The  table  below  shows  the  information  provided  by  Member  States  for  the  number  of 
payment  accounts  that  were  switched  in  the  period  between  2016  and  2021.  Not  all 
information is available in all Member States, so the table has certain gaps. In particular, data 
for  2021  were  not  yet  available  at  the  time  of  collection  for  all  Member  States.  Similarly, 
given the late transposition in  some Member States, a switching service  may not  have been 
available in 2016 or 2017, or the data were not collected for these years. In addition, in some 
Member States, data have not always been collected on a yearly basis, but rather for a longer 
period. 

Furthermore, the data provided may not be fully comparable given different methods of data 
collection.  For  instance,  in  some  Member  States,  it  is  mandatory  for  credit  institutions  to 
report the data periodically  (or on an ad hoc basis). However, in  other  Member States, data 
may  only  be  collected  on  a  voluntary  basis  or  only  from  a  sample  of  credit  institutions.  In 
addition, in some cases, the figures provided by some Member States for 2016 may include 
switches  that  took  place  during  that  year  in  the  months  before  the  entry  into  force  of  the 
Directive  (e.g.  if  a  similar  switching  service  had  already  existed  in  those  Member  States 

With regard to  Germany, the  Commission is  following the  situation after its comparison  website  was 

5 
subject to an injunction presented by a local consumer association. 
6 
Czechia,  Germany,  and  the  Netherlands  have  their  respective  comparison  websites  run  by  a  private 
operator. Poland has two compliant comparison websites, one of which is run privately. The rest have a publicly 
run comparison website. 

5 

 
 
 
 
 
 
 
                                                           
before the implementation of the Directive). For all these reasons, it is difficult to draw clear 
conclusions.  

  Table 1: Number of yearly switches 7 

On  the  basis  of  the  data  available,  the  table  shows  that  there  are  big  differences  between 
Member States. In some Member States, a considerable number of switches have taken place 
(e.g. Denmark or France), with, in some cases, an increasing trend; however, the figures are 
very low in others (e.g. Bulgaria, Greece, Cyprus, Malta, Portugal or Romania). 8   

7 
Estonian data refer to the period 10.1.2017-31.7.2018 and 1.8.2018-31.7.2020. German data refer to the 
period  18.9.2016-30.6.2018  and  2019.  For  the  calculation  of  the  total  number  of  switches  per  year,  figures 
collected for a longer period than a year  (e.g. in Estonia and Germany) have been distributed proportionally to 
individual years. 
8  
A number of factors may be affecting the level of switching. 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 lack of 

6 

Country201620172018201920202021TotalBelgium44 96037 87369 86868 50471 14984 699377 053Bulgaria0302207Czechia61 41874 45889 41275 10775 636376 031Denmark184 674189 643188 204190 402199 334205 5821 157 839Germany467 5491 222 549Estonia541Ireland1 4215 2214 4406 6682 36920 119Greece002147Spain1772 92824 90328 008France1 106 0001 214 0001 361 0001 251 0001 387 0006 319 000Croatia702 0263 9431 6762 76610 481Italy54 27696 628129 740148 653150 956210 280790 533Cyprus0036615Latvia006632103201Lithuania2742591 3349449003 711Luxembourg2514774775195072 231Hungary221 6161 0691 3862 3322 0218 446Malta0000Netherlands77 47367 34590 79860 52951 37642 043389 564Austria127 46597 364119 097110 25997 911552 096Poland32 16834 20634 20649 82422 67412 579185 657Portugal22124045119Romania425698Slovenia3 1148 21510 77710 50210 58443 192Slovakia9 60610 8965 43656 50831 65953 126167 231Finland23 04541 27727 26425 067116 653SwedenTotal512 457       2 196 617    2 177 9262 666 5772 032 0132 185 79211 771 382  Number of switches that have taken place each year755 000179362 
 
 
                                                           
 
b)  Number (and proportion) of rejected switching applications 

Member States provided the information included in the table below regarding the number of 
applications  for  switching  that  were  rejected  in  the  period  between  2016  and  2021.  The 
proportions  have  been  calculated  by  taking  the  number  of  switches  that  took  place  and  the 
number of applications for switches that were refused as a percentage of total applications  9. 
Similar to the above, information about the number of rejected switching applications is not 
complete. In addition, in some Member States, data on rejected applications are not collected 
at all. Furthermore, the data provided may again not be fully comparable given the different 
methods of data collection used by Member States.  

Table 2: The number and proportion of applications for switching that have been refused 10 

financial literacy and the assumption that switching would only lead to limited savings; a desire not to lose one’s 
bank account number; and the risk that payments may go astray. (See for details Article 28 report). 
9 
Possible withdrawal of applications could not be considered (given a lack of data). 
10 
Estonian data refer to the period 10.1.2017-31.7.2018 and 1.8.2018-31.7.2020. German data refer to the 
period  18.9.2016-30.6.2018  and  2019.  For  the  calculation  of  the  total  number  of  switches  per  year,  figures 
collected for a longer period than a year (e.g. in Estonia and Germany) have been distributed proportionally to 
individual years. 

7 

Country2016%2017%2018%2019%2020%2021%Total% TotalBelgium5 8577.61 %5 9096.52 %11 7663.03 %Bulgaria0-00 %0-00 %00 %0-00 %Czechia3 9566.05 %3 6754.70 %5 9566.25 %5 7097.06%19 2964.88 %DenmarkGermany1.24 %9 3091.95 %18 8091.52 %EstoniaIreland00 %00 %00 %00 %00 %00 %Greece0-0-00 %00 %120 %112.50 %Spain20253.30 %1 78637.89 %24 67749.77 %26 66548.77 %France35 3862.53 %40 0323.10 %38 8362.72 %114 2541.78 %Croatia67.89 %1476.76 %2876.78 %895.04 %1324.55 %6615.93 %Italy8 90114.09 %11 04510.26 %19 44613.03 %17 98010.79 %18 05210.68 %24 33610.37 %99 76011.21 %Cyprus0-0-00 %00 %00 %00 %Latvia0-0-68.33 %38.57 %76.36 %167.37 %LithuaniaLuxembourg10.40 %20.42 %30.63 %30.57 %20.39 %110.49 %Hungary312.00 %49423.41 %30422.14 %35920.57 %40614.83 %37015.47 %1 93618.65 %Malta0-0-0-0-Netherlands11 22714.29 %11 70411.42 %9 05813.02 %4 6818.35 %4 72710.11 %41 3979.61 %Austria530.04 %820.08 %1740.15 %970.09 %540.06 %4600.08 %Poland2010.40 %378614.31 %3 9872.10 %Portugal415.38 %942.86 %511.11 %611.76 %2416.78 %Romania2739.13 %1217.65 %3928.47 %SloveniaSlovakia7607.33 %7736.62 %3496.03 %4 7277.72 %2 6317.67 %4 9308.49 %14 1707.81 %Finland1040.45 %310.08 %150.05 %130.05 %1630.14 %SwedenTotal11 02133 08838 68785 268106 04179 310353 415  2.91 %9 5000 %25 %Number of applications for switching which have been refused each year and proportion of applications that have been refused 
 
 
 
 
                                                                                                                                                                                     
It  seems  that  the  number  of  refusals  for  switching  applications  is  generally  low.  However, 
there  seem  to  be  considerable  differences  between  individual  Member  States,  with  few 
showing high numbers (e.g. Spain, Hungary or Romania). While credit institutions should in 
principle not refuse any switching, credit institutions may refuse to close a payment account, 
if  there  is  an  outstanding  obligation  11.  Other  cases  could  concern  incomplete  or  incorrect 
switching application forms. 

5.  NUMBER  OF  CREDIT  INSTITUTIONS  OFFERING  PAYMENT  ACCOUNTS 
WITH BASIC FEATURES, THE NUMBER OF SUCH ACCOUNTS THAT HAVE 
BEEN OPENED AND THE PROPORTION OF APPLICATIONS FOR PAYMENT 
ACCOUNTS WITH BASIC FEATURES THAT HAVE BEEN REFUSED 

In order to foster financial inclusion, Article 16 of the Directive establishes the right of access 
to a payment account with basic features (PABF) for all consumers legally resident in the EU. 
PABFs  have  to  be  offered  to  consumers  by  all  credit  institutions  or  a  sufficient  number  of 
credit institutions to guarantee access thereto for all consumers in their territory. 

a)  Number of credit institutions offering PABFs 

In most Member States, all credit institutions that provide standard payment accounts have to 
offer  payment  accounts  with  basic  features.  In  other  Member  States  (see  table  below),  only 
some  credit  institutions,  i.e.  those  fulfilling  specific  criteria  set  by  the  individual  Member 
States, are obliged to offer payment accounts with basic features. In all these Member States, 
however, the obliged credit institutions seem to generally cover a large market share in terms 
of number of payment accounts. 

11  
Article  10(4)  e)  of  PAD  states  that  the  transferring  payment  service  provider  shall  close  the  payment 
account on the date specified in the authorisation if the consumer has no outstanding obligations on that payment 
account and provided that the actions listed in points (a), (b) and (d) have been completed. 

8 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                           
Table 3: Member States 12 where only some credit institutions offer PABFs 

b)  Number of payment accounts with basic features (PABFs) 

The information on the number of PABFs provided by Member States and set out in the table 
below  is  not  complete  for  certain  years.  In  addition,  in  some  Member  States,  the  credit 
institutions may not distinguish between a standard payment account and a PABF, so that no 
data  on  PABFs  exist.  Similarly,  the  information  may  not  always  be  comparable  due  to 
different data collection methods. Beyond that, a lack of comparability is also due to the fact 
that, in some Member States, only some credit institutions offer PABFs as a specific product 
whereas  other  credit  institutions  do  not  distinguish  different  types  of  accounts.  In  these 
countries,  the  figures  thus  cover  only  the  PABF  offered  as  a  specific  product.  As  a 
consequence, it is again difficult to draw firm conclusions. 

12 
In Slovakia, only credit institutions providing all the banking services linked to a payment account with 
basic features as part of their business activity to the consumers are obliged. For instance, if a credit institution 
provides these services, but solely to business clients, this credit institution is not obliged. In the case of some 
purely  internet  banks,  which  do  not  have  physical  branches,  if  they  do  not  provide  cash  withdrawals  at  the 
counter of the physical branches of banks, they too are not obliged. 

9 

CountrySpecific Member State criteria to offer PABF by credit institutionsTotal number of credit institutions obliged to offer a PABF (as compared to the total number of credit institutions providing payment accounts) and their market shareGreeceAllcreditinstitutionsthatprovidepaymentservicestoconsumers,withtheexceptionofcreditinstitutionsthatprovide payment  account with solely online facilities12CroatiaCreditinstitutionswhosetotalassetsaccordingtotheauditedannualfinancialstatementsfortheprecedingyearexceedHRK 15 billion.7 out of 2194%CyprusTheCentralBankofCyprusapprovedtheexemptionfromthis obligation for 3 locally incorporated banks.25 out of 2898,50%LuxembourgThepaymentserviceprovidermusthaveatleast25agenciesinLuxembourgandmustholdatleast2,5%ofcovereddeposits. 5100%MaltaCreditInstitutionshavingaphysicalbranchnetworkoffiveor more5These 5 banks have the majority of the market share in the countryNetherlandsMajorbanks.Theparticipatingbankshaveagreedtothisinadedicated covenant.5Approx. 85%SlovakiaBanksandbranchesofforeignbankstotheextentthattheyprovideallthebankingserviceslinkedtoapaymentaccountwith basic features as part of their business activity.11 
 
 
 
 
 
 
 
 
 
 
 
 
                                                           
Table 4: Number of PABFs 13 

The information provided in the table shows that a considerable number of PABFs have been 
opened during the period reported. 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 (e.g., Czechia, Cyprus, Greece, Lithuania). Nevertheless, uptake was rather 
low in some others (e.g., Bulgaria, Croatia, Latvia, Poland and Romania). 14 

13 
Cypriot data refer to the period 1.7.2017-31.5.2018; 2019, 2020 and 2021 and most of them are due to 
reclassifications from existing basic payment accounts to category PABF on the initiative of the bank. Estonian 
data refer to the period 10.1.2017-31.7.2018 and 1.8.2018-31.7.2020. German data refer to the period 18.9.2016-
30.6.2018 and 2019. For the calculation of the  total  number of PABFs per  year, figures collected for a  longer 
period than a year (e.g. in Estonia and Germany) have been distributed proportionally to individual years. 
14  
A number of different reasons may explain the relatively low number of PABFs. Firstly, the percentage 
of  people  with  a  bank  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  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. (See for details 
Article 28 report). 

10 

Country201620172018201920202021TotalBelgium1 5451 2481 8679 2249 44223 326Bulgaria766153093355273372 199Czechia39 97337 15516 2077 996101 331DenmarkGermany144 194684 694Estonia373 022Ireland9 15338 84743 97447 11614 410153 500Greece198 258286 141223 640189 090196 3871 093 516Spain7 64513 83118 77540 251France55 97960 09355 97951 66836 05634 594294 369Croatia47106175140186654Italy10 99414 30412 45012 51211 25112 55774 068Cyprus1 38038 5033 63643 948Latvia1421316685169593Lithuania26 0007 6007 1007 6005 40053 700Luxembourg11932241715207HungaryMalta364 8586 4103 19614 500NetherlandsAustria6 8774 6683 5453 3234 80923 222Poland5 7747 26213 036Portugal12 73611 99217 20147 58730 07325 935145 524Romania2 6544 2036 857Slovenia724302632521981 215Slovakia1 3097978727415555464 820Finland54 92611 0329 95111 0999 74996 757SwedenTotal281 843772 134677 742700 778524 847287 9653 245 309144 455228 567Total number of payment accounts with basic features that have been opened each year429540 500 
 
 
                                                           
c)  Number  (and  proportion)  of  applications  for payment  accounts  with  basic  features 

that have been refused 

The data on the number of applications for PABFs that have been refused were obtained by 
Member States (see table below). The proportions have been calculated by taking the number 
of  PABFs  opened  and  the  number  of  applications  for  a  PABF  that  have  been  refused  as  a 
share  of  total  applications  15.  The  data  are  subject  to  the  same  caveats  as  before:  not  all 
information is available and the data may not be fully comparable. 

Table 5: Number and proportion of applications for a PABF that have been refused 16 

15 
Possible application withdrawals have not been considered (due to lack of data). 
16 
Cypriot  data  refer  to  the  period  1.7.2017-31.5.2018;  2019,  2020  and 2021  and proportions  have  been 
calculated  on  the  basis  of  new  applications,  without  taking  into  account  the  possible  reclassifications  or 
conversions to PABFs. Estonian data refer to the period 10.1.2017-31.7.2018 and 1.8.2018-31.7.2020. German 
data  refer  to  the  period  18.9.2016-30.6.2018  and  2019.  For  the  calculation  of  the  total  number  of  refused 
applications of PABFs per year, figures collected for a longer period than a year (e.g. in Estonia and Germany) 
have  been  distributed  proportionally  to  individual  years.  Latvian  data  also  reflect  information  on  terminated 
PABFs at the consumer’s initiative. 

11 

Country2016%2017%2018%2019%2020%2021%Total% TotalBelgium30.19 %00 %00 %20.02 %60.06 %110.05 %Bulgaria00 %00 %00 %00 %00 %00 %00 %Czechia60.02 %260.07 %450.28 %1291.59 %2060.20 %DenmarkGermany2.63 %5 1583.45 %19 7582.80 %EstoniaIreland230.25 %170.04 %250.06 %50.01 %20.01 %720.05 %Greece00 %00 %1430.06 %2 8701.50 %1 6190.82 %4 6320.42 %Spain70.09 %9866.65 %2 22710.60 %3 2207.41 %France00 %00 %00 %00 %00 %00 %0 %Croatia00 %65.36 %00 %21.41 %00 %81.21 %Italy2242.00 %1711.18 %1711.35 %2371.86 %1711.50 %2361.84 %1 2101.61 %Cyprus1036.95 %121.68 %682.05 %1843.09 %Latvia138.39 %6031.41 %11864.13 %12759.91 %2211.52 %34036.44 %Lithuania30.01 %60.08 %20.03 %00 %110.02 %Luxembourg10.83 %00 %414.29 %00 %16.25 %62.82 %HungaryMalta00 %1172.35 %961.48 %682.08 %2811.90 %NetherlandsAustria1311.87 %1122.34 %802.21 %812.38 %2174.32 %6212.60 %Poland1041.77 %1762.37 %2802.10 %Portugal1851.43 %1501.24 %2651.52 %5811.21 %3581.18 %3151.20 %1 8541.26 %Romania20.08 %00 %20.03 %Slovenia2122.58 %92.05 %124.36 %10.40 %94.35 %524.10 %Slovakia40.30 %10.13 %00 %10.13 %20.36 %80.17 %Finland360.33 %220.22 %20.02 %20.02 %620.06 %SwedenTotal4 0897 8504 3627 7006 2622 55532 8181.00 %Total number of PABF which have been refused each year and the proportion of applications for PABF that have been refused12.5 %2.8 %14 600 
 
 
 
 
 
                                                           
The data indicates that the rejection rates of PABF applications are generally very low and in 
a small  number of Member States (e.g. Bulgaria or  France) there  are no  rejections  at  all  17. 
However, in a few Member States, a slightly higher level of rejections exists, whereas the rate 
of rejections in one Member State (Latvia) seems particularly high. 

6.  CONCLUSION 

The  timespan  of  the  data  collected  and  the  differences  in  data  collection  methods  makes  it 
difficult  to  draw  definitive  conclusions  on  the  impact  of  the  Directive  on  the  ground.  The 
report confirms however that the main measures of the Directive, regarding transparency and 
comparability, switching service, and the right to a payment account with basic features, have 
all generally been put in place. 

With the caveats of data gaps and varying data collection methods, the data seem to indicate 
that, in some Member States, a considerable number of switches have taken place, with  - in 
some cases - an increasing trend. However, the figures are very low in other Member States. 
The  number  of  refusals  on  switching  applications  seems  generally  low,  albeit  high  in  few 
Member States. 

As  regards  PABFs,  the  data  shows  that,  in  most  Member  States,  all  credit  institutions  that 
provide  standard  payment  accounts  have  to  offer  payment  accounts  with  basic  features. 
However, in  other Member States, only some credit institutions,  i.e. those fulfilling specific 
criteria set by the individual Member States, are obliged to offer payment accounts with basic 
features.  In  these  latter  cases,  the  obliged  credit  institutions  nevertheless  seem  to  generally 
cover a large market share. In addition, the data show that a considerable number of PABFs 
have  been  opened  during  the  period  reported,  albeit  only  few  in  some  Member  States. 
Nevertheless,  there  has  been  a  significant  uptake  in  some  Member  States  with  a  previously 
higher percentage of unbanked population. The rates of rejection of PABF applications seems 
generally  very  low.  However,  in  a  few  Member  States,  a  slightly  higher  level  of  rejections 
exists, whereas the rate of rejections in one Member State seems particularly high. 

In  order  to  ensure  more  complete  availability  and  comparability  of  data  going  forward,  the 
Commission  is  working  with  Member  States  to  agree  the  relevant  data  sets  to  be 
collected/provided.  

17  
specific credit institution to provide a PABF to a consumer whose applications for a PABF have been rejected. 

For example, the refusal rate in France is 0%. In this Member State there is a mechanism to designate a 

12