Here in Europe we are eagerly awaiting the review of the European Union's 2007 Directive on "Payment Services in the Internal Market" and the regulation on "Cross-border Payments in the Community."
(Just to remind you, a directive means that each of the EU's 27 member states will be asked to transpose the directive into national law whereas an EU regulation supersedes all national law.)
The key driver behind this review is the European Commission's Green Paper, "Towards an integrated European market for card, Internet and mobile payments," and the report of the same name from the European Parliament's Committee on Economic and Monetary Affairs.
When you work your way through the mountain of documentation that has been published in the last 13 months on this, I believe it comes down to three crucial points that will impact the future health of the European ATM Industry.
Firstly, we need to see Europe's regulators tightening up the regulation of payment systems, i.e., the card schemes. The ATM channel's revenues are suffering through declining interchange and the restrictions placed on direct charging.
Whilst the default position of the 2007 PSD is to permit charging (under certain rules on transparency), we do have countries in Europe who exercised their right to ban charging on card payments when they were transposing the directive into national law. But alas in the countries where there are no bans, we are hindered by the card schemes' own rule books that prohibit direct charging.
Secondly we really need to see the Independent ATM Deployers included in the provisions of this directive. Here in Europe we have many IADs already offering "payment services" to card holders using their ATMs — charitable donations in the UK, mobile phone top-up in most markets, top-up to mobile payment schemes such as Barclays Bank's Pingit in the UK, converting mobile person-to-person payments into cash in Poland and Spain, and person-to-person remittances in Poland and the UK. So one has to ask what logic is keeping the IADs out of the Payment Services Directive?
And finally we would like to see recognition of the distinct difference between ATM direct charging and surcharging on a POS card payment. ATMIA Europe has put pen to paper to make this clear distinction: Direct charging at an ATM is the means by which the ATM operator charges a fee direct to the card holder for the provision of services, be it cash provision, person-to-person payment, mobile phone top-up, etc. Whereas surcharging at a point-of-sale card payment terminal is a means by which the merchant can levy an additional charge on a card payment (credit and/or debit) in order to cover the fees charged by the card networks.
In summary, a direct charge at an ATM is not an additional charge on top of a payment but the means by which the card holder is paying direct for the services of that ATM operator.
We are awaiting the publication of this PSD review in April with huge anticipation here in Europe.
Flora Hamilton joined the ATM Industry Association (ATMIA) with responsibility for Europe in October 2009. Trained in business science, Flora has previously worked for the Public Relations Consultants Association, BBC Worldwide, the Press Association and Association for Measurement & Evaluation of Communication.