assessment of the migration efforts deemed necessary, the ecb preferred migration end date for the credit transfer scheme would be november 2012. as a logical consequence of this, the ecb would envisage an end date of november 2013 for the direct debit scheme. however, the actual end date for migration to sepa will be determined by the european council and the european parliament by means of the co - decision procedure. overall, not having a regulation is not an option. we all look forward to the upcoming draft legislative proposal by the european commission and we hope that the proposal is published as soon as possible. 2. towards a competitive european payment card market calls for an additional european card scheme the sepa card framework developed a few years ago presents three ways of establishing a card scheme that achieves the overall objective of citizens being able to use the scheme ’ s cards anywhere in the euro area. this could be achieved by : 1. replacing a national scheme with an international scheme ( assuming the latter complies with the principles of sepa ) ; 2. developing a payment card scheme covering the entire euro area, either by means of alliances with other card schemes or through expansion ; 3. co - branding with an international card scheme. the eurosystem expressed reservations regarding the first and third options. it was felt that the first option – the “ replacement strategy ” – would lead to a situation where visa europe and mastercard progressively became the sole providers of card payment services offered by banks in the euro area. the third option – “ co - branding ” – was deemed less favourable because it would perpetuate the existing situation, where schemes are protected from competition by national borders. if the majority of schemes were to opt for co - branding and this situation were to become permanent, the market would remain highly fragmented. sepa customers would not benefit from economies of scale or competition. national schemes would, in all probability, retain national business. cross - border transactions would be effected only through visa europe and mastercard. instead, the eurosystem expressed a preference for the emergence of an additional european card scheme. this was the position of the eurosystem four years ago, and it remains its position today. there is a clear risk of the vast majority of the national card schemes – some of them rather efficient as they are – leaving their market share to visa europe and mastercard and competition being reduced to a duopoly. this would mean less choice, less competition, and less european governance.

therefore, an additional european card scheme can have a lot of benefits. three initiatives are currently under way with a view to creating an additional european card scheme : the euro alliance of payment schemes ( eaps ), monnet and payfair. further initiatives are obviously not excluded. it seems that the development of a proper financing model is probably the most important issue from banks ’ point of view. and here again, uncertainty about multilateral interchange fees is considered an obstacle to any progress in this field. the criticism that there is a lack of clarity in this area does not fully recognise the commitments made recently by mastercard and visa europe on multilateral interchange fees. one should also recognise that the european as well as national competition authorities have already provided some guidance. however, here too, regulation might provide a solution of last resort and a possibility to look at the business model in the context of other business rules and market circumstances that presently stand in the way of an effective market providing efficient services against optimal prices to consumers and other customers. overall, i believe that an additional european scheme – safe and efficient as the best performing existing ones – is a necessary element of an integrated and competitive market. separating card schemes from processing entities the concept of separating schemes from processing entities is one of the core elements of sepa to guarantee open access. the sepa credit transfer and direct debit schemes are built on this principle. this concept should be applied in the card market, too. indeed, banks should have a range of options to choose from as regards the processing of card payments. the separation of schemes from processing entities has many dimensions, comprising operational, informational, financial / accounting, commercial and legal separation. major efforts need to be made by individual schemes in order to achieve effective separation in these various domains. three things are needed in the area of card processing. 1. first, the processing of card transactions should use the same set of message standards as the processing of direct debits and credit transfers ( i. e. the iso 20022 standard ). 2. second, a framework is needed for the processing of card transactions. 3. and third, the various infrastructures need to develop the rules and standards that are needed in order to establish technical interoperability. in december 2009 the european payments council ( epc ) agreed to update the pe - ach / csm framework to include card transactions. however, work still needs to take off on this. cards standardization another important issue is cards standardisation