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: 2025-09-11
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, 11.9.2025  COM(2025) 485 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            
 
 
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 SWITCHING APPLICATIONS THAT HAVE BEEN REFUSED ............... 6 

5. 
NUMBER OF CREDIT INSTITUTIONS OFFERING PAYMENT ACCOUNTS WITH 
BASIC FEATURES, THE NUMBER OF SUCH ACCOUNTS THAT HAVE BEEN OPENED 
AND THE PROPORTION OF REFUSED APPLICATIONS FOR PAYMENT ACCOUNTS 
WITH BASIC FEATURES .................................................................................................................. 9 

6. 

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

1 

 
 
 
 
 
 
 
 
 
 
 
1. 

INTRODUCTION 

The Payment Accounts Directive (PAD) 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  PAD.  Under  Article 27  of  PAD,  the  Commission  is 
required to prepare a report providing the following information: 

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

comparison websites pursuant to Article 7 of PAD; 

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  solely  on  data  provided  by  the  Member  States. 
However, the data contains certain gaps (e.g. when information was not available in a Member 
State). Data collection methodologies and sources may also have been different across Member 
States, which may make comparisons and assessment difficult. 

This is the second report based on Article 27 of PAD, covering information relating to 2022 
and 20231. It has been prepared on the basis of a questionnaire that was discussed and agreed 
with government representatives from the 27 EU Member States. 

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

AND 6 

Chapter II of PAD introduces rules to ensure that payment service providers make available 
clear and transparent information about fees related to payment accounts. Its two primary goals, 
as stated in the PAD recitals, are to (i) strengthen the internal market for retail banking; and (ii) 
empower consumers to effectively compare offers and make informed choices. 

The first step in achieving these goals is to establish a standardised terminology, as outlined in 
Article 3  of  PAD.  To  accomplish  this,  Member  States  are  equipped  with  a  list  of  the  most 
common fee-based services linked to a payment account, developed through a comprehensive 
and  step-by-step  approach.  This  standardised  terminology  is  laid  down  in  a  Delegated 
Regulation2. It also serves as the foundation for the subsequent articles in Chapter II, as payment 
service  providers  are  required  to  use  these  agreed-upon  terms  in  order  to  comply  with  the 
remaining provisions of the chapter. 

1 The report also contains updated/complete data for 2021 which was also requested from those Member States 
that did not have the data for 2021 available yet at the time of the first report. 
2 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, C/2017/6451,  OJ  L  6, 
11.1.2018, p. 3. 

2 

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

a)  Article 4: fee information document and glossary 

Article 4  establishes  that  payment  service  providers  must  provide  consumers  with  a  fee 
information document in good time before entering into a contract for a payment account. The 
document must be provided on paper or another durable medium and contain the standardised 
terms and corresponding fees for each service offered by the provider. The presentation of the 
fee information document is subject to precise rules laid down in an Implementing Regulation3. 
Additionally, payment service providers must make  available a glossary  of the standardised 
terms and definitions and ensure that the fee information document and glossary are readily 
accessible to consumers at any time, free of charge, and in various formats, including electronic 
form on their websites and premises, as well as on paper or another durable medium upon the 
consumers’ request. 

As regards the timely provision of the fee information document to consumers, as stipulated by 
Article 4(1), the data indicates general compliance among payment service providers. This 
conclusion  is  drawn  from  conducted  surveys,  inspections  or  other  supervisory  checks  and 
analyses (e.g. BE, CZ, DE, ES, FR, HR, HU, IE, IT, LU, LV, MT, PL, PT, RO, SI)4, and the 
very low incidence of complaints or lack of other indications of providers’ non-compliance (e.g. 
AT,  BG,  CY,  DK,  EE,  EL,  ES,  FI,  LT,  NL,  SE,  SK).  Overall,  these  findings  suggest  that 
providers are compliant. The information documents are also presented to consumers in various 
formats,  including  physically  in  branches  and  digitally  on  websites.  In  that  respect,  the 
Netherlands highlighted that while fee information documents are available on websites, they 
are  not  always  easy  to  find  for  consumers.  France  noted  the  recent  observation  of  a  credit 
institution providing pricing information via a QR code, deeming it in compliance if it links to 
a  durable  medium  that  can  be  downloaded,  printed  or  recorded,  and  if  the  information  is 
available upon consumer request. 

Regarding  the  requirement  of  payment  service  providers  to  make  available  a  glossary  of 
standardised terms, as outlined in Article 4(4), the data points to general compliance among 
payment  service  providers.  This  conclusion  is  drawn  from  surveys,  inspections  or  other 
supervisory checks and analyses (e.g. BE, BG, CZ, DE, FR, HR, HU, IE, IT, LU, LV, MT, PL, 
PT, RO, SI), and the very low incidence of complaints or lack of other indications of providers’ 
non-compliance  (e.g.  AT,  CY,  DK,  EL,  ES,  FI,  LT,  NL,  SE,  SK).  Overall,  these  findings 
suggest that providers are compliant. 

On the requirement to make available to consumers (and non-customers) at any time on the 
website  and  on  the  premises  the  fee  information  document  and  glossary,  as  required  by 
Article 4(5),  the  data  suggests  general  compliance  by  payment  service  providers.  This 
conclusion is again drawn from surveys, inspections or other supervisory checks and analyses 
(e.g. BE, BG, CZ, DE, FR, HR, HU, IE, IT, LU, LV, MT, PL, PT, RO, SI), and the very low 
incidence of complaints or lack of other indications of providers’ non-compliance (e.g. AT, CY, 

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 Country codes used in this report: AT (Austria), BE (Belgium), BG (Bulgaria), CY (Cyprus), CZ (Czechia), DE 
(Germany), DK (Denmark), EE (Estonia), EL (Greece), ES (Spain), FI (Finland), FR (France), HR (Croatia), HU 
(Hungary),  IE  (Ireland),  IT  (Italy),  LT  (Lithuania),  LU  (Luxembourg),  LV  (Latvia),  MT  (Malta),  NL 
(Netherlands), PL (Poland), PT (Portugal), RO (Romania), SE (Sweden), SI (Slovenia), SK (Slovakia). 

3 

 
 
 
DK, EL, ES, FI, LT, NL, SE, SK). Overall, these findings suggest that providers are compliant. 

In a limited number of cases, anomalies were identified regarding the use of non-standardised 
terms and the provision of the fee information document and glossary. The respective providers 
were  instructed  to  address  the  issues  detected  with  appropriate  remedial  actions,  but  no 
sanctions were imposed as providers took measures to ensure compliance (e.g. ES, IT, PT). In 
France,  one  establishment  that  failed  to  provide  the  fee  information  document  received  an 
injunction to comply after repeated instances of non-compliance. However, nearly all Member 
States reported that no enforcement actions have been initiated regarding infringements of 
Article 4. 

Most  Member  States  indicated  that  consumer  detriment  decreased  as  a  result  of  the 
requirements laid down in Article 4. However, several Member States pointed out that there is 
insufficient data to fully assess this issue with certainty. 

b)  Article 5: statement of fees 

Article 5  of  PAD  governs  the  statement  of  fees.  The  statement  must  include  a  detailed 
breakdown of all fees incurred for services linked to a payment account. To ensure consistency 
and  clarity,  the  European  Commission  has  enacted  an  Implementing  Regulation5  that 
standardises the presentation format of the statement of fees and introduces a common symbol. 
This obligation aims to promote transparency and help consumers better understand the fees 
associated with their payment accounts. 

In  terms  of  the  obligation  to  deliver  at  least  annually  and  free  of  charge  a  statement  of  all 
incurred fees, as set out in Article 5, the data indicates general compliance among payment 
service  providers.  This  conclusion  is  drawn  from  surveys,  inspections  or  other  supervisory 
checks  and  analyses  (e.g.  CZ, DE, FR,  HR,  HU, IE,  IT, LU, LV,  MT, PL, PT, SI), and  the 
absence of complaints or lack of other indications of providers’ non-compliance (e.g. AT, BE, 
BG, CY, EL, ES, FI, LT, PL, RO, SE, SK). Overall, these findings suggest that providers are 
compliant. 

In a limited number of cases, shortcomings have been identified, e.g. in Hungary and Portugal 
regarding  to  the  compliance  with  information  requirements  of  the  statement.  Some 
shortcomings  have  also  been  identified  in  Italy  on  the  incorrect  categorisation  of  products 
outside the scope of the PAD as well as the provision of the statement of fees less frequently 
than required. These shortcomings required the competent authorities to take action to ensure 
compliance (e.g. HU, IT). However, nearly all Member States reported that no enforcement 
actions have been initiated regarding infringements of Article 5. 

Most  Member  States  indicated  that  consumer  detriment  decreased  as  a  result  of  the 
requirements laid down in Article 5. However, several Member States pointed out that there is 
insufficient data to fully assess this issue with certainty. 

c)  Article 6: information for consumers 

Article 6 of PAD requires payment service providers to use in their contractual, commercial 
and marketing information to consumers, the standardised terms.  This means that consistent 
and clear language must be used to help consumers understand the services and fees associated 

5 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. 

4 

 
 
 
with their payment accounts. While payment service providers are allowed to use their brand 
names in the fee information document and statement of fees, these brand names can only be 
used as a secondary designation of the services. 

On  the  obligation  to  incorporate  standardised  terms  in  the  contractual,  commercial  and 
marketing information to consumers, as specified in Article 6(1), the data points to general 
compliance  among  payment  service  providers.  This  conclusion  emerges  from  surveys, 
inspections or other supervisory checks (e.g. BE, CZ, DE, FR, HR, HU, IE, IT, LU, LV, MT, 
PL,  PT,  RO),  and  the  absence  of  complaints  or  lack  of  other  indications  of  providers’  non-
compliance (e.g. AT, CY, BG, DK, EE, EL, ES, FI, LT, NL, SE, SI, SK). The data suggests 
that overall, providers are generally compliant. 

Concerning how frequently payment service providers include their brand name in the fee 
information document and the statement of fees, the overall observation is that providers 
often do include the brand name.  Several  Member States indicated that  they did  not have 
sufficient data to assess this issue. 

Regarding  enforcement  actions  related  to  infringements  of  Article 6,  almost  all  Member 
States reported that no such actions have been undertaken. Portugal noted that, between 
2022 and 2023, three infringements were detected, which were followed up with warnings to 
comply. However, no further enforcement action has been taken. Based on a survey carried out 
in  2022,  France  highlighted  that  one  payment  service  provider  did  not  include  all  required 
information.  However,  following  an  injunction,  the  provider  complied  with  the  Article  6 
obligation under PAD. 

Most  Member  States  indicated  that  consumer  detriment  decreased  as  a  result  of  the 
requirements laid down in Article 6. However, several Member States pointed out that there is 
insufficient data to fully assess this issue with certainty, and a couple other Member States also 
highlighted a likely limited impact of Article 6. 

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

Article 7 requires 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.  It also establishes that the comparison website may be operated either by a private 
operator or by a public authority, that it is operationally independent, discloses the owner of the 
website,  sets  out  clear,  objective  criteria  which  the  comparison  is  based  on,  uses  plain  and 
unambiguous language, is up to date, covers a significant part of the market and provides an 
effective procedure to report incorrect information on published fees. 

Almost all Member States6 have at least one operational comparison website, as required 
by  Article 7.  Most  Member  States  have  assigned  the  responsibility  for  creating  and 

6 In Germany, a new  comparison website  provided by the public authority BaFin became available in  January 
2025.  The  previously  available  comparison  website  of  a  private  provider  was  not  compliant  with  the  PAD 
according to a German court decision. The main reason was an insufficient market coverage. Also, the information 
on the website was not always up to date because the banks were not obligated to report their data to the provider. 
Therefore,  banks  are  now  obliged  to  continuously  report  the  relevant  data  to  BaFin.  Although  some  private 
comparison websites have been available online for a few years, Italy is also still in the process of developing a 
comparison website that complies with the requirements of Article 7 of the PAD. 

5 

 
 
 
 
updating  the  website  to  a  public  authority.  In  Ireland,  Poland  and  Spain  several  private 
websites exist in addition to a public website. In Denmark and Czechia, the available websites 
are run by private operators. In Finland, Netherlands and Sweden, both public and private actors 
are involved. 

Croatia noted that its website also distinguishes between different types of accounts, such as 
basic accounts for consumers belonging to a vulnerable group. Some websites also provide 
information on other products or other comparison websites related to different products 
that exist in the respective Member States. Additional products include credit cards, insurances, 
mortgage loans, consumer credits and savings accounts. Except for some private websites in 
Czechia,  none  of  the  publicly  available  comparison  websites  in  Member  States  appear  to 
provide personalised advice to consumers. 

Overall, comparison websites appear to be updated on a regular basis. Furthermore, several 
Member States emphasise that they require providers to notify website operators of any change, 
before or at the latest when the new conditions take effect (e.g. BG, DE, ES, HR, HU, LT, MT, 
LV, PL, PT, RO, SI, SK). 

Only  a  few  Member  States  reported  that  the  reporting  mechanism  for  incorrect 
information  on  published  fees  had  been  triggered  (e.g.  BE,  BG,  EL,  FI,  FR,  LU,  MT), 
typically requiring only minor corrections. Overall, this suggests that correct information is 
displayed on the comparison websites. On correcting errors, France highlighted its automatic 
verification process, which conducts quality checks on the information published on the website 
during the entry stage. Malta also emphasised that its competent authority reviews all changes 
before  publication  on  the  comparison  website  to  prevent  incorrect  information  from  being 
published. 

Several Member States have also launched specific public awareness campaigns through 
various communication channels, such as television, radio and social media (e.g. BE, DE, 
EE, HR, IE, PT). In addition, several other Member States disseminate relevant information on 
related  public  websites,  press  releases  and  reports  (e.g.  BG,  ES,  FI,  LV,  NL,  PL,  SE,  SI). 
Moreover,  Austria  and  Hungary  pointed  out  that  payment  service  providers  must  inform 
consumers about the availability of the comparison website. 

Only a few Member States have carried out specific assessments of their websites, or plan 
to do so in the future. For instance, in 2020, an evaluation of the Dutch comparison website was 
carried  out,  including  questionnaires  targeted  at  both  users  and  payment  service  providers. 
Based on the evaluation’s feedback, clear information on when the website is updated has been 
added. Luxembourg’s website was reviewed in 2023 and was made more consumer-friendly 
and handier. While Spain did not conduct a broad assessment, some evidence suggested that 
consumers experience difficulties in usage and that information does not always appear to be 
entirely up to date with current consumer preferences. Therefore, Spain is currently reviewing 
its website. Malta mentioned that it carries out periodic exercises to capture website visits and 
assess the effectiveness of the comparison website. Romania will run a project co-financed by 
the  European  Social  Fund.  The  aim  is  to  reduce  administrative  burden  for  individuals  and 
businesses in consumer protection, which includes improving the comparison website so that it 
is more user-friendly. 

6 

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

a)  Payment accounts that have been switched 

PAD establishes a quick procedure for consumers who wish to switch their account from one 
bank to another in the same Member State. 

Table 1 shows the number of payment accounts that have been switched  between 2016  and 
2023. Not all information is available in all Member States and there are certain gaps in the data 
in the table. Given the late transposition in some Member States, a switching service may not 
yet have been available in 2016 or 2017, or the data has not been collected for these years. In 
addition, in some Member States, the data has not always been collected annually. 

Furthermore, the data provided may not always be comparable given different methods of data 
collection.  While  in  some  Member  States  it  is  mandatory  for  credit  institutions  to  report 
periodically (or on an ad hoc basis), data may only be collected on a voluntary basis or only 
from a sample of credit institutions in other Member States. In some cases, the data provided 
by Member States for 2016 may include switches that took place in the months before the entry 
into force of PAD (where e.g. a similar switching service had already existed in these Member 
States before the implementation of PAD). 

Since the data collection exercise began, 17.6 million payment accounts have been switched 
using the switching service. 

Table 1: Number of yearly switches 

7 

Country20162017201820192020202120222023Total switchesBelgium037 87369 86868 50471 14978 73964 64674 763465 542Bulgaria030220007Czechia61 41874 45889 41275 10775 47797 96359 896533 731Denmark184 674189 643188 204190 402199 334205 582180 721182 6111 521 171Germany755 000467 549482 131467 783493 3942 665 857Estonia17936275616Ireland1 4215 2214 4406 6682 3695 74625 8772 03953 781Greece2 4993 0692 8228 390Spain1772 92824 90349 33770 47970 486218 310France1 106 0001 214 0001 361 0001 251 0001 387 4251 566 0971 243 8619 129 383Croatia702 0263 9431 6762 7662 1282 19114 800Italy54 27696 628129 740148 653150 956181 613159 671181 5611 103 098Cyprus003663119Latvia0066321038644331Lithuania2742591 3349449001 0088775 596Luxembourg2514774775195073772352 843Hungary221 6161 0691 3862 3322 0322 2345 64816 339Malta000000Netherlands77 47367 34590 79860 52951 37636 73139 45238 959462 663Austria127 46597 364119 097110 25997 91192 76787 024731 887Poland32 16834 20634 20649 82422 6749 55211 63818 667212 935Portugal221240453852209Romania42561481627415Slovenia3 1148 21510 77710 50211 4458 5757 47060 098Slovakia9 60610 8965 43656 50831 65953 12641 37634 235242 842Finland23 04541 27727 26425 06718 82427 02822 158184 663SwedenTotal359 6402 520 2471 962 0782 666 7562 031 9062 702 6452 863 1782 529 07617 635 526 
 
 
 
Given  the  data  gaps  and  the  lack  of  fully  comparable  data7,  it  is  difficult  to  draw  clear 
conclusions with respect to the uptake of the switching service or to identify any clear trend 
over  the  time  horizon.  It  is  however  possible  to  note  significant  differences.  While  in  some 
Member States a considerable number of switches have taken place, in other cases the figures 
appear very low. Of particular note is the high level of switching in France (1.2 million in 2023, 
down from 1.5 million in 2022), where the process has become well established.  

According  to  Member  State  responses,  the  low  number  of  switches  in  some  other  Member 
States  can be  attributed  to  a number of factors.  These include  (i) a  lack  of awareness  about 
switching services; (ii) a lack of demand (due to minimal differences between payment accounts 
and  use  of  multiple  accounts  with  different  providers);  (iii)  negative  perceptions  about  the 
difficulty of the process; (iv) inertia; (v) difficulties to identify better value alternatives; or (vi) 
credit  facilities  or  other  tied  services  with  a  financial  institution  which  may  be  difficult  to 
transfer; and (vii) inconvenience connected to changing an IBAN number. Some Member States 
have  taken  action  to  further  ease  the  account  switching  process8.  Low  uptake  of  switching 
services in some Member States may merit further assessment and discussion. 

b)  Number (and proportion) of rejected switching applications 

Table 2 shows the number of switching applications that have been rejected between 2016 and 
2023.  The  proportions  have  been  calculated  by  dividing  the  number  of  rejected  switching 
applications by the total number of applications9. The information is incomplete because data 
on rejected applications is not collected in some Member States. Furthermore, the data provided 
may not be fully comparable given the different methods of data collection. 

7 For example, certain data includes all types of accounts, not limited to payment accounts. 
8 In Portugal, for example actions have been taken to address concerns about the low numbers of account switching. 
The  Bank  of  Portugal  has  provided  guidance  in  the  form  of  a  Circular  letter  indicating  that  payment  service 
providers (i) must make available a switching account form, (ii) should make account switching available through 
digital  channels  when  opening  a  payment  account  is  also  available  through  the  said  means,  (iii)  must  inform 
consumers  of  the  reasons of  the  switch  account  refusal,  (iv)  must  make  available  forms with  the  new  account 
information, to be presented by consumers to their creditors and/or debtors, when the consumer chooses to execute 
such task (instead of the payment service provider), (v) must make available in their websites, information about 
payment accounts switching and (vi) must provide their staff with the knowledge about the switching service. 
9 (Number of refusals) / (Number of refusals + Number of switches). 

8 

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

In  view  of  the  data  gaps  as  well  as  different  methodologies,  it  is  difficult  to  draw  firm 
conclusions. However, it is possible to note very significant differences across Member States 
and to provide indications as to possible explanations, as provided in Member State responses 
to the questionnaire. The percentage of refusals reached 85% in Romania (2023), 49% in Spain 
2020, 29% in Poland (2023), 27% in Ireland (2023), 27% in Hungary (2023), while in most 
other Member States the proportion of rejected applications is much lower10. Member States 
gave  several  reasons  to  explain  why  switching  applications  were  refused.  These  include  (i) 
errors related to the switching application form (missing, incorrect or inconsistent information, 
ineligible account types, illegible/missing signatures etc.); (ii) incomplete documentation; (iii) 
lack of cooperation between banks;  (iv) negative  account  balances; (v) not  meeting specific 
deadlines; or (vi) cancellation of the application by the user.  

10 In the case of Denmark, it is estimated by the Danish Banking Association, Finance Denmark, that no switching 
applications have been refused. Similarly in Lithuania, it is estimated that no switching applications have been 
refused. 

9 

Country2016%2017%2018%2019%2020%2021%2022%2023%Belgium5 8577,6%7 3088,5%6 4939,1%9 89011,7%BulgariaCzechia3 9566,1%3 6754,7%5 9566,2%5 7097,1%4 3945,5%5 0504,9%5 0637,8%Denmark0Germany9 5001,2%9 3092,0%20 9274,2%26 1395,3%32 4586,2%EstoniaIreland4 49014,8%77027,4%Greece20,1%00Spain20253,3%1 78637,9%24 67749,8%20 59029,4%24 94326,1%19 44221,6%France35 3862,5%40 0323,1%39 2642,8%51 6813,2%46 0233,6%Croatia67,9%1476,8%2876,8%895,0%1324,6%853,8%793,5%Italy8 90114,1%11 04510,3%19 44613,0%17 98010,8%18 05210,7%22 42111,0%18 00110,1%21 76710,7%CyprusLatvia68,3%38,6%76,4%22,3%24,3%Lithuania000Luxembourg10,4%20,4%30,6%30,6%20,4%00,0%0Hungary30,1249423,4%30422,1%35920,6%40614,8%37415,5%54919,7%2 04926,6%Malta000Netherlands11 22714,3%11 70411,4%9 05813,0%4 6818,4%3 5978,9%3 5498,3%4 32710,0%Austria530,0%820,1%1740,1%970,1%540,1%510,1%460,1%Poland2010,4%3 78614,3%3 98629,4%4 07725,9%7 63129,0%Portugal415,4%942,9%511,1%611,8%511,6%35,5%Romania2739,1%1217,6%6129,2%74,1%4185,4%Slovenia400,3%590,7%290,4%Slovakia7607,3%7736,6%3496,0%4 7277,7%2 6317,7%4 9308,5%4 5169,8%3 81910,0%Finland1040,4%310,1%150,1%130,1%140,1%220,1%150,1%SwedenTotal9 6642,6%37 1591,5%35 9731,8%85 2683,1%106 0415,0%128 1094,5%149 7195,0%153 4545,7% 
 
 
 
 
 
 
 
 
5.  NUMBER  OF  CREDIT  INSTITUTIONS  OFFERING  PAYMENT  ACCOUNTS 
WITH BASIC FEATURES, THE NUMBER OF SUCH ACCOUNTS THAT HAVE 
BEEN OPENED AND THE PROPORTION OF REFUSED APPLICATIONS FOR 
PAYMENT ACCOUNTS WITH BASIC FEATURES  

a)  Credit institutions offering payment accounts with basic features (PABF) 

In most Member States, all credit institutions that provide standard payment accounts have to 
offer payment accounts with basic features (BE11, BG, CZ, DK, DE, EE, IE, ES, FR, IT, LV, 
LT,  HU,  NL12,  AT,  PL,  PT,  RO,  SI,  FI,  SE).  In  other  Member  States,  only  some  credit 
institutions, i.e. those meeting 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 
generally cover a large market share in terms of number of payment accounts. 

Table 3: Member States where only certain credit institutions offer PABFs 

Country 

Specific  Member  State  criteria  to  offer 
PABF by credit institutions 

Greece 

Croatia 

Cyprus 

All credit institutions that provide payment 
services  to  consumers,  except  for  credit 
institutions  that  provide  payment  account 
with only online facilities 
Credit  institutions  whose  assets  exceed 
EUR 1.99  billion  must  offer  PABF.  Other 
credit institutions may offer PABF 
All  credit  institutions  operating  in  Cyprus 
are obliged to offer PABF, except for 3 very 
small locally incorporated banks 

Malta 

Luxembourg  Credit institutions with at least 25 agencies 
in Luxembourg and holding at least 2.5% of 
covered deposits must provide PABFs 
Credit 
institutions  having  5  or  more 
branches in Malta are obliged to offer PABF 
institutions  providing  all 
Only  credit 
banking  services  linked  to  a  payment 
account with basic features as part of their 
business activity to consumers 

Slovakia 

Total  number  of  credit  institutions 
obliged  to  offer  a  payment  account 
with  basic  features  (as  compared  to 
the total number of credit institutions 
providing  payment  accounts)  and 
their market share 

7  banks  out  of  20  (assets  exceeding 
EUR 1.99 billion), representing 94% of 
market share 
14  credit  institutions  representing  a 
market share around 94% 

5 credit institutions which taken together 
represent most of the market 

5  credit  institutions  offer  PABF  with  a 
market share of 93.7% 
10 credit institutions 

b)  Number of Payment Accounts with Basic Features (PABFs) 

The information on the number of PABFs provided by Member States and set out in Table 4 is 
incomplete  for  certain  years.  In  some  Member  States,  credit  institutions  do  not  distinguish 
between a standard payment account and a PABF, so that no data on PABFs exists. Similarly, 

11 14 credit institutions offer PABF end 2023. They account for 95% market share of consumer payment 
accounts. 
12 Most banks offer PABFs as the most restricted version of their standard payment account: some banks offer 
PABFs as a specific product which is different from a standard payment account. 

10 

 
 
 
 
 
 
 
 
the  information  may  not  always  be  comparable  due  to  different  data  collection  methods.  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 therefore only cover the PABFs offered as a specific product. 

Table 4: Number of PABFs opened each year 

Given the data gaps and the lack of comparable data, it is difficult to draw firm conclusions13. 
Since it is not a requirement under Article 27, data is not available to indicate the total number 
of  outstanding  PABFs  at  each  year  end.  The  information  provided  in  Table  4  shows  that  a 
considerable number of PABFs have been opened during the time period, reaching almost 
2 million in 2023. The very high number of account openings in Romania is explained by the 
fact that the data show all types of account opening and is not limited to PABFs. Similarly in 
Greece,  the  high  number  of  opening  new  accounts  comes  from  the  fact  that  customers  use 
standard  accounts  as  PABFs.  The  number  of  new  accounts  opened  in  France,  Italy14  and 
Slovakia is strikingly low. 

13 For example, the number for Germany shown in 2018 is a consolidated number for the years 2016-2018, or data 
in some Member States is not available for all years. 
14 In Italy, the obligation to offer the ‘basic account’ is deemed to be fulfilled if the PSP provides the PABF as a 
specific product or if the PSP offers a ‘standard’ payment account which is free of charge at least for the services 

11 

Country20162017201820192020202120222023TotalBelgium1 5451 2481 8679 2249 44212 77142 67232 083110 852Bulgaria766153093355273372082 1574 564Czechia39 97337 15516 2077 99611 60910 9021 682125 524Denmark1 9207 5039 81919 242Germany540 500144 194122 425261 886175 3671 244 372Estonia144 455228 567192 70098 900664 622Ireland9 15338 84743 97447 11614 41034 520121 365136 992446 377Greece198 258286 141223 640189 090387 149428 824521 4612 234 563Spain7 64513 83118 77518 39927 26517 143103 058France55 97960 09355 97951 66836 05634 59426 052320 421Croatia471061751401865 1122 6498 415Italy10 99414 30412 45012 51211 25112 44714 91319 211108 082Cyprus4291 38038 5033 63742 03025 206111 185Latvia14213166851693 6638095 065Lithuania26 0007 6007 1007 6007 2467 3645 36668 276Luxembourg119322417153933279Hungary5335687611 862Malta364 8586 4103 1962 7552 51119 766NetherlandsAustria6 8774 6683 5453 3234 8096 8847 02837 134Poland5 7747 26214 12523 06623 75273 979Portugal12 73611 99217 20147 58730 07325 93542 43241 265229 221Romania2 6544 203422 984529 852557 9241 517 617Slovenia724302632529872 6862 5797 269Slovakia1 3097978727415555355094875 805Finland54 92611 0329 95111 0999 74910 45718 00015 753140 967Sweden486 108445 853228 1351 160 096Total146 718555 3001 029 701834 109391 5161 617 0932 239 0511 955 125 
 
 
 
 
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 has been gathered by 
Member States (Table 5). The proportions have been calculated by taking the number of PABFs 
opened and the number of applications for PABFs that have been refused as the total number 
of applications15. 

Table5: Number and proportion of applications for PABF that have been refused 

The data is not available for all MS and may not be fully comparable. It is therefore not possible 
to draw firm conclusions. Nevertheless, the data indicates that the rates of rejection of PABF 
application are generally very low. 

The situation across the Member States varies significantly regarding the reasons for refusals. 
Based on the questionnaire replies, the main reasons for refusals include: (i) compliance with 
money  laundering  and  know  your  customer  requirements;  (ii)  the  customer  already  holds  a 
payment account; (iii) the customer has had past negative antecedents with the bank; (iv) issues 
with documentation; or (v) the applicant is not resident in the EU. 

6.  CONCLUSION 

The  report  confirms  that  the  main  PAD  measures  on  transparency  and  comparability,  the 
switching service and the right to a payment account with basic features, are generally in place. 
However,  the  differences  in  Member  States’  data  collection  methods  and  the  persistence  of 

and number of transactions to be included in the PABF; in the latter case, the pre-contractual information on the 
account shall specify that it replaces the ‘basic account’. 
. 
15 Possible withdrawal of applications has not been considered (due to lack of data). 

12 

Country2016%2017%2018%2019%2020%2021%2022%2023%Belgium30,2%00,0%020,0%60,1%170,1%100,0%0Bulgaria000,0%00000401,8%Czechia60,0%260,1%450,3%1291,6%420,4%530,5%734,2%DenmarkGermany14 6002,6%5 1583,5%5 3254,2%6 5452,4%2 9681,7%Estonia2 4371,2%1 9171,9%Ireland230,3%170,0%250,1%50,0%20,0%20,0%7 2495,6%4 6423,3%Greece001430,1%2 8701,5%1 7180,4%2 8380,7%2300,0%Spain70,1%9866,7%2 22710,6%2 17510,6%2 4578,3%3 42616,7%France000002 9537,9%4 3314 63615,1%Croatia065,4%021,4%0521,0%632,3%Italy2242,0%1711,2%1711,4%2371,9%1711,5%2301,8%1691,1%2091,1%Cyprus1036,9%120,0%681,8%1070,3%910,4%Latvia138,4%6031,4%11864,1%12759,9%2211,5%30,1%60,7%Lithuania30,0%60,1%2070,1%380,5%230,4%Luxembourg10,8%0414,3%016,3%00HungaryMalta01172,4%961,5%682,1%582,1%361,4%NetherlandsAustria1311,9%1122,3%802,2%812,4%2174,3%370,5%340,5%Poland1041,8%1762,4%5864,2%8583,7%1 0214,4%Portugal1851,4%1501,2%2651,5%5811,2%3581,2%3151,2%3 5537,7%2 3795,5%Romania20,1%01 2540,3%1 4650,3%1 7180,3%Slovenia2122,6%92,1%124,4%10,4%90,9%50,2%481,8%Slovakia40,3%10,1%010,1%20,4%0010,2%Finland360,3%220,2%20,0%20,0%30,0%230,1%430,3%Sweden1 0420,2%1 2490,3%9410,4%Total4390,3%5500,1%15 3111,5%7 7000,9%6 2621,6%16 0541,0%33 5371,5%24 5451,2% 
 
 
 
 
 
 
 
significant data gaps make it difficult to draw firm conclusions about the extent of the benefits 
that the introduction of PAD has given European consumers. 

With those caveats in mind, we can nonetheless draw the following tentative conclusions: 

•  The  information  and  transparency  requirements  under  Articles  4,  5  and  6  are 
generally being complied with, suggesting an overall reduction of consumer detriment. 
However, the availability of more comprehensive and robust data would be needed to 
draw  firm  conclusions  on  the  positive  impact  of  these  provisions  on  European 
consumers. 

•  Comparison  websites  are  fully  operational  in  almost  all  Member  States.  Several 
Member  States  have  also  conducted  public  awareness  campaigns  and  provide 
information  through  various  communication  channels,  which  can  play  a  vital  role  in 
raising consumer awareness. Only a few Member States have assessed or plan to assess 
their  comparison  websites.  Regular  assessments,  incorporating  feedback  from  both 
consumers and service providers would ensure more user-friendly interfaces as well as 
more relevant and easily accessible information for consumers. 

•  On payment account switching, the switching service was used by over 2.5 million 
customers in 2023, down from the previous high in 2022 of 2.86 million. Since 2016, 
there have been a total of 17.6 million account switches. In some Member States, the 
switching service is frequently used, in contrast to a number of other Member States 
where it is barely used at all. The reasons for such discrepancies are not fully clear and 
may require further investigation. However, anecdotal evidence provided by Member 
States  suggests  that  inertia,  lack  of  awareness  and  demand,  perceived  complexity 
(including around extrication from existing tied arrangements), customer loyalty, lack 
of obvious benefits to be gained from switching or inconvenience of changing IBAN 
may all play a role. 

•  There are also significant differences across Member States regarding the number of 
switching  applications  that  are  refused.  Among  the  reasons  for  refusal  given  by 
Member  States  are  (i)  errors  related  to  the  switching  application  form  (missing  or 
incorrect  information,  inconsistent  customer  data,  ineligible  account  types,  incorrect 
forms,  incorrect  IBAN,  illegible/missing  signatures);  (ii)  too  short  deadlines;  (iii) 
incomplete  documentation;  (iv)  lack  of  cooperation  between  banks;  (v)  negative 
account  balances;  (vi)  not  meeting  specific  deadlines;  or  (vii)  cancellation  of  the 
application by the user. 

•  On  Payment  Accounts with  Basic  Features  (PABFs),  gaps  still  remain  in  the  data 
where some Member States have not provided the number of new account openings. 
The Commission does not hold data on the total number of PABFs at the end of each 
year and cannot therefore indicate how many people now hold such accounts. There are 
significant  differences across Member States  regarding the  number of new account 
openings.  This  may  be  partly  explained  by  differences  in  the  way  banks  offer  such 
features  to  their  customers.  For  example,  in  some  cases  there  is  no  differentiation 
between PABFs and standard accounts that incorporate the basic features of a PABF. 
While end-of-year data on the total number of payment accounts with basic features is 
not available. From the data provided by Member States it is possible to identify year-
on-year increases – with the number of new account openings reaching almost 2 million 
in 2023. 

13 

 
 
•  The  rate  of  rejections  of  PABFs  applications  varies  significantly  across  Member 
States. The reasons for this include concerns over money laundering, the fact that the 
customer already holds  another payment  account,  past  negative  experiences with  the 
bank, issues with documentation or because the person is not resident in the EU. In total, 
24 545 refusals to open basic payment accounts were registered in 2023, representing 
1.2% of the total number of basic payment accounts opened. 

The  Commission  will  follow  up  the  findings  of  the  report,  including  the  low  uptake  of  the 
switching service or high rejection rates for PABFs in some Member States, discuss them with 
Member States and explore whether further actions could be beneficial, including at Member 
State level. The Commission will also continue to work with Member States to ensure more 
robust and comparable data going forward. 

14