RD208 - ETNO Reflection Document on the European Commission Document on the draft Directive on the New Legal Framework for Payments in the Internal Market Version 5.0 (26/11/04)

ETNO is grateful to the European Commission for the opportunity to follow the debate on the New Legal Framework for Payments in the Internal Market within the Payment Systems Market Group and being able to provide comments on the last version on the future Directive.

ETNO members welcome the Commission’s attempts to clarify and update the existing framework and develop an efficient market for payments services in the EU that fully takes into account new technologies. ETNO appreciates the Commission’s efforts throughout the consultation process to better understand telecommunications operators’ business activities, given the risk that this proposal may have on the provision of third party services offered by telecommunications operators and the extensive implications for existing and future business activities this were to be the case. Against this background, ETNO believes that it is crucial that the final Commission proposal fully follows the core principles of proportionality and technological neutrality. It should also strive to ensure a clear separation between the areas of application of the E-Money-Directive and the New Legal Framework for Payments, to allow for the rapid and successful development of truly pan-European electronic payments (mobile payments, micro-payments and those over the Internet) services.