EuroCommerce position paper Online e-payments

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1 EuroCommerce position paper Online e-payments 16 September 2011 EuroCommerce welcomes the opportunity to comment on online payment issues. We carried out a brief members' survey and consulted within the retail industry to ascertain the levels of e-commerce use and the problems encountered, with special emphasis on payments. The information gathered is included in this paper. However, we are certain that much more research must be done to ascertain the true picture. 1. The relevance of e-commerce for the retail sector E-commerce is an important and growing market for the retail sector and is clearly becoming more and more popular with consumers. However, it is apparent that the current level of usage of online selling within the retail sector is by and large much lower than it could be: reality is lagging far behind potential. Clearly there are some sectors where it is very advanced and others where it is not used at all. It should also be recognised that the suitability of online sales varies with product type. Delivery is also an issue for some types of product. Most members surveyed did have a website through which they would accept payment for goods, but the proportion of their business done online was still, in the main, very small. Most said their intention was to grow online sales. Within the next five years, internet sales have the distinct potential to take over a large segment of telephone and mail order, especially for the younger consumer. 2. Major challenges in e-commerce The majority of members surveyed operate online payments only at the national level, although some members have opted for having a separate internet site per country. Some of the reasons given for the national-only nature were specific to the business (e.g. services which operate only nationally, food cannot be transported, one mentioned lack of consumer interest in buying online.) General Challenges Legal issues: Consumer legislation: consumer protection legislation varies across member states. Currency: Currency conversion issues make the assessment of price and profit difficult re non-eu member states. Taxation: Some members reported that taxation status can alter if the percentage of sales made across border exceeds a certain level. VAT is also a problem, since rates vary locally. Practical and general issues: Language: having one website in numerous languages can be technically complex. Some members prefer to have separate national sites, but this tends to be companies which

2 have physical presence in several member states. Separate sites also avoids problems with currency, tax etc. Higher fraud risk: the wider the geographical spread of payments gives rise at least to a perception of higher fraud risk although actual levels of fraud cannot easily be calculated by the retailer. Also not all of the payment methods, which businesses in a particular member states may use and trust, are available across the EU. (See Specific Payment Issues section below.) Cost/ difficulty of cross-border delivery: the longer the distance, the greater the delivery costs. Also tracking goods becomes more complex. Long-distance postage can give rise to liability issues if goods fail to arrive. 3. Specific Payment issues 3.1. Characteristics of online e-payments As an ideal goal, the retail sector seeks online payment systems which: have a high acceptance network - as wide as possible a reach amongst consumers and available equally across the EU use payment models which carry low fees for retail ensure payment guarantee/non-repudiation for merchants operate with settlement time up to 1 day (as set by PSD) are trusted, secure, with low fraud levels, for both merchants and consumers have security features which are technically easy to use for both retailer and consumer offer speed, efficiency, payment guarantee allow scope for retailer reward programmes How far do existing solutions meet these requirements? At present these characteristics are best met by card payments which use 3-D secure and online-banking based e-payments. Traditional card payments, overlay services, wallet and voucher solutions meet only around half of the expected characteristics Card payments We must distinguish between credit card and debit card. Almost all retail members who responded accept as payment types the international credit card schemes MasterCard and Visa. These may be co-branded with own-brand/ customer fidelity cards. There are still a far lower number of retailers who accept debit cards as online payments. Few in Europe take Amex. PayPal is also used by some and there are local variations: in some member states, cheques are still accepted; some have cash or card payment on delivery/collection. ideal is used where available. Most of the payment types listed in the questionnaire have pros and cons. None of them satisfy all the requirements. However there are 3 major weaknesses: Fees The single most important issue with card payments online (as in POS) is the cost involved from interchange fees. The most generally used payment method for internet sales is the credit card, which carries the highest fee levels. The issue of surcharge has also badly backfired in online payments. Some operators apply disproportionate levels of surcharge, which has caused a consumer backlash. None of the retail members mentioned imposing a surcharge for online payment by any method Security a) Transaction security There are still significant issues with authentication, e-identity and e-signature which undermine the security of online payments. Internet fraud is on the increase. The almost EUwide use of EMV at POS has made skimming etc very difficult, so fraud is moving online. 3- D secure, or other similar local methods, was used by some respondents. However, security tools for internet card payments have distinct problems: 2 of 5

3 Lack of consistency: The different types of security system used (processes and interfaces) lead to confusion and lack of confidence among consumers. No global fraud and real-time reporting mechanism. Security is complicated and costly and requires a high-level of IT support. It is not possible for the retailer to identify levels of fraud in online payments. Low level of information: i.e. 3-D secure does not allow the retailer to identify why a payment fails (forgotten pass-word, abandoned purchase, failure of 3-D secure service or fraud) Several suggestions were made for improvements: Currently, the customer is given the option to opt out and not register for the security system this could be altered. The use of dynamic passwords rather than static passwords (i.e. systems which use an extra device to generate a one-time PIN for each payment transaction). More consistency: the different types of security processes and interfaces can lead to confusion in the customer and the sale may be lost. Risk-based security where a customer is rated according to their payment history and if they are low risk, no authentication screen is presented to the customer. b) Data security PCI-DSS requirements are very onerous and extremely costly for merchants. Most question the level, cost and increasing complexity of PCI requirements. Most members felt that data security should be the responsibility of banks and payment institutions. Some merchants suggest that the responsibility for retaining card data should be removed from the merchant altogether. There are a number of proposals for systems which would avoid the retention of sensitive data by merchants: these should be actively encouraged and pursued. Suggested improvements: Suggestions have been made for the wider use of a one-off transaction number to identify the transaction so that the merchant would not even receive the card or account information into his system (tokenisation). If card details are only visible to and kept by the bank, this would relieve merchants of the burden of PCI-DSS. Fraud data: Information on fraud is not available to merchants. It is therefore not possible to gauge the true extent or cost of fraud and the level of protection appropriate to combat it. If the fraud issue is to be tackled, full data on online fraud must be made available by the banking sector to the central authorities. It must be compiled and made publicly available Technology Lack of interoperability of e-identity across Europe. Lack of interoperability of European standards for payments Lack of interoperability of European vis-à-vis international standards Need for mutual recognition of certification approval (e.g. by European certification approval authority) Barriers to innovation and harmonisation (see below) 3.3. Alternative payment mechanisms EuroCommerce fully supports the promotion and development of alternative payment methods online. Currently their availability and use is patchy. In the Netherlands, a number of our members use ideal and are very happy with it. Similarly, Sofortbanking is also popular in Germany. A number of members also use PayPal. There is little information on the use of voucher solutions Barriers to innovation and harmonisation 3 of 5

4 To optimise innovation we need to foster the development of multiple channel secure payment solutions which can allow use of different available mechanisms card, mobile applications, credit transfer, direct debit etc. However, there are a number of significant barriers: No access to customer bank accounts for e-commerce transaction settlement: to allow innovation, new non-banking providers must have secure access to account data. Differences among the standards required both at member state level and between European/international standards Lack of transparency towards consumers: as long as consumers are not properly informed of the fees associated with different payment methods, they are not able to judge which is the most efficient method and choose accordingly. The continued marketing of expensive payment methods to consumers through free gifts distorts the consumer s perception to the detriment of more cost-efficient alternatives. 4. Retail contribution to the challenges The retail sector has consistently campaigned for more transparent, efficient and costbalanced payment methods. EuroCommerce contributes fully to all consultations and works with the Commission and the ECB to ensure that the issues are properly understood. At the same time, EuroCommerce does everything possible to ensure our membership if fully informed on all payment issues on which it is active. At the face-to-face level, the retail sector seeks to respond to the needs and wishes of consumers. Retail welcomes all types of payment method, as long as these are not detrimental to business in cost terms. On security, the retail sector does all in its power to ensure the security of all payment transactions whether face-to-face or online and has invested significant sums in the shift to EMV and in PCI compliance. The sector will continue to work to its best ability to ensure efficient, secure payment methods for its customers. 5. Legal status The retail sector has no specific views on the legal status which should be held by a payment provider. What is important to the retail sector is that the PSP should be trustworthy, secure, and able to provide an efficient cost-effective service. We would support the opening of the market to all operators able to provide such a service. The current bank/card scheme domination in payments has had a detrimental effect on fees and inhibits the emergence of new payment models. 6. Governance EuroCommerce is committed to being involved in the governance of SEPA and participates as fully as possible in existing user groups. We see a clear need for an expansion of the involvement of the retail sector and other major stakeholders at an equal level with payment providers. The governance structure must be improved to allow for this. Online payments cannot be viewed as a separate sector within payments which should have some kind of separate governance structure. The development of online payment solutions must involve all players in the payments market i.e. payment providers, solution providers, merchants of all types and consumers. It is also crucial that innovative and start-up payment operators are actively included to counter-balance already established players. In our view this would be best done by a reassessment and a reorganisation of SEPA governance as a whole. Please see joint position paper on SEPA governance from the SEPA End-Users Committee, September Future Issues 4 of 5

5 We would stress that payments using mobile devices and mobile phones are also e-payments and it would be a mistake to regard internet payments and mobile telephone payments as distinct. Questions of the underlying models of the payment mechanism, barriers to entry to new providers, the business models and fee structures are common and have to be tackled in a way which addresses all e-payments. These new technologies will blur the boundaries between traditional face-to-face payments and online payments. Payments using a mobile phone will mean that consumer will want to make e-payments in shops, restaurants etc i.e. situations where terminals are attended. The range of payment options for traditionally face-to-face payments will therefore increase greatly by means of mobile phone technology. In this paper, however, we have confined ourselves to internet payments as requested in the EU SEPA Council questionnaire. Contact details : The EuroCommerce expert on payments is: Ruth Milligan, Legal Expert on Payment Systems: 5 of 5

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