PSD3 and payment services

ftl experts have more than ten years of experience in working with entities which provide payment services, including the largest Polish and European providers. Thanks to our active participation in Polish and European working groups created under the auspices of Polish and EU authorities, we are able to prepare our clients to operate not only in the current legal and regulatory realities but also in the one yet to come. Members of the ftl team have represented and advised clients in more than twenty successful licensing proceedings, both before the Polish Financial Supervision Authority (KNF) and other EU regulatory bodies (including the National Bank of Lithuania and the UK Financial Conduct Authority).

PSD3 and Open Finance

On June 28th, 2023 the European Commission published a package of newly created legislation (PSD 3, PSR, Digital Euro and FIDAR) revolutionizing the landscape of the payment services industry. Despite the fact that these regulations are sitll at the drafting stage, ftl is actively participating in the EU legislative process and is already preparing our Clients for their implementation through dedicated trainings, expert analysis’ or internal audits.

The experience of ftl’s experts in the implementation of new regulations for financial market entities indicates that it takes at average over an year for an organization to adapt to such complex new regulations. In order therefer to meet this objective, ftl is already preparing our Clients for the new regulatory reality, both in terms of open banking and open finance. The experience of ftl experts shows that entities that were the first to effectively and efficiently implement the new regulations gained a significant market advantage over their competitors.

Licensing proceedings

The extensive experience of ftl experts in handling proceedings for obtaining a licence to provide payment services and for obtaining an entry in the register of payment service providers allows us to provide comprehensive support for such proceedings. Thus, we offer our clients support that goes beyond the formal handling of the application process, guaranteeing full substantive input, including support that is necessary in the preparation of all documents required for the successful completion of the proceedings, such as procedures, plans or documents used to demonstrate compliance with regulatory requirements. We also advise on the preparation of business and financial documents necessary for proceedings before regulatory authorities.


Handling the implementation of new solutions in the payment services market is one of ftl’s key specialisations. The many years of practice in this area allow us to offer optimal regulatory solutions, taking into account both the basic aspect of compliance (ensuring compliance with regulations) and additionally the opportunity aspect (benefiting from the opportunities created by regulations for business development). Our proposals for legal and regulatory solutions are designed to maximise our clients’ business needs and the specific product considering the conditions that facilitate its commercialisation.

Contract documentation

ftl offers the development of contractual documentation used both within the framework of relations with users of payment services (terms and conditions, model contracts, information clauses, etc.) and in relations with entities cooperating with the provider in the delivery of services (insourcers, agents, other providers, etc.). The documents we develop ensure not only the fulfilment of the applicable legal requirements, but also a high level of transparency and clarity in the use of the services. The formulation of the payment service contractual documentation, whether in a B2C or a B2B relationship, is adapted to the provider’s communication policy, also where it is carried out in a less formal manner.

Internal processes

ftl supports payment service providers in shaping their internal policies and processes to ensure the security and compliance of their business with the law. The solutions we offer and formalised documentation are developed on a case-to-case basis, subject to the specifics of a particular entity, the services it offers and its overall legal and business situation. Such an approach allows us to optimise the use of resources and streamline the management of individual processes.