Challenges for retail payment systems Keynote speech by Daniela Russo Director General Payments and Market Infrastructure of the European Central Bank At the Conference on card, internet and mobile payments Brussels, 4 May 2012 Ladies and gentlemen, Speaking right before lunch is both an opportunity and a challenge. It is an opportunity because, at this time of the day, people have developed a healthy appetite. But it is also a challenge because expectations would probably be for something tastier than the food for thought I have on offer. Nevertheless, I will give it a try, and I hope that my remarks will be not too hard to digest. By way of an apéritif, I would like to refer to a recent interview given by Christine Lagarde, Managing Director of the IMF, in which she asserted, with regard to the current crisis, that there is no other solution for Europe than to increase its integration. 1 I would like to take up and develop this statement with regard to retail payments. This will enable me to look at the theme of today s conference from a broader perspective. As you know, the Eurosystem has welcomed and strongly supports the European Commission s initiative to launch a public dialogue on the present landscape of card, internet and mobile payments in Europe. Our views on the consultation are available on the ECB s website and I feel it would not be too interesting merely repeating the feedback already given and published. I would rather offer you some considerations on a few selected issues. 1 Article published in Les Echos, 25 April 2012. 1
In this regard, I have prepared a three-course menu for you: my starter deals with the public interest in integrating and modernising retail payments in Europe; the main course emphasises the importance of SEPA migration; and my dessert highlights similarities and divergences in the European and global agendas. Appetiser: public interest in SEPA As the starter determines the first and overall impression of a menu, I would propose as a starter a few considerations on the public interest in integrating and modernising retail payments in Europe, which is the pivotal point also for our discussion of SEPA. The safety and efficiency of retail payments concern every single citizen and every business in Europe. In the event of a payment failure or malfunction, both day-to-day life and day-to-day commerce would become extremely difficult. Correspondingly, increased efficiency in payments would help to free up time and resources, benefiting not only individuals and entities, but also society as a whole. Thus, arguing for or against efforts to integrate and modernise retail payments from the financial sector s perspective simply does not provide the full picture. As epitomised in the SEPA project, the integration and modernisation of cashless payments in Europe is an issue of public interest. The costs of retail payments to society are not negligible. In a recent (country) study, it was established that the social cost of retail payments can be up to 1.5% of GDP. 2 Simulations based on a more efficient selection of payment instruments lead to a significantly lower figure (1.09% of GDP). Recent research has also shown that migration to efficient electronic retail payments not only allows for cost savings, but also stimulates overall economic growth, consumption and trade. 3 Among different payment instruments, this relationship is strongest for card payments, 2 Turján, A., Divéki, É., Keszy-Harmath, É., Kóczán, G. and Takács, K. (2011), Nothing is free: a survey of the social cost of the main payment instruments in Hungary, Occasional Paper Series, No 93, Magyar Nemzeti Bank, Budapest. 3 ECB, forthcoming. 2
followed by credit transfers and direct debits. Retail payment transaction technology itself is also associated positively with real economic aggregates. It has often been observed that the main beneficiaries of the SEPA project will be the end users. Payment service providers, on the other hand, often feel that the creation of SEPA puts them under pressure from different directions: eroding returns due to increasing competition, substantial investment needs to keep up with customer demands and technological progress, and last but not least a more critical stance by competition authorities on issues such as interchange fees. In a context where the crisis and the subsequent new regulatory requirements are significantly increasing costs, this does not provide the right appetite to invest in retail. All this is true, yet it is only one side of the coin. The last few years have led to a better recognition of the importance of retail banking and retail payments in generating revenue for banks. Retail payment revenues account for up to 25% of total bank revenues. 4 Unlike other sources of income, they have a reliable and stable character. Furthermore, there is a fundamental relationship between retail payment business and overall bank performance, which shows that banks perform better, in terms of costs/profits, in countries with more developed retail payment services. 5 Bringing the two sides of the coin together, I would like to call on all stakeholders involved to keep up their efforts towards modernising and integrating retail payments in Europe, as this is the only way to ensure the sustained growth of non-cash payments and to realise the resulting benefits. Main course: SEPA migration The main course is often the heaviest meal and therefore hardest to digest. That is why I am addressing here the difficult issue of SEPA migration. Following the adoption of Regulation (EU) No 260/2012, it has been remarked on several occasions that phase 1 of the SEPA 4 Retail payments: integration and innovation, Joint conference held by the ECB and De Nederlandsche Bank, 25-26 May 2009. 5 Hasan, I., Schmiedel, H. and Song, L. (2009), Return to retail banking and payments, Working Paper Series, No 1135, ECB, Frankfurt am Main, December. Published in Journal of Financial Services Research, 2011. 3
project, i.e. the integration phase, is coming to a close, and that the main focus should now be shifted to phase 2, which is the innovation phase. While moving ahead sounds more appealing, it should not be an excuse for escaping responsibility to keep commitments taken a while ago. In this sense, I think that at this stage we should not neglect some important issues. While the Regulation has set the timeline for migration to SCT and SDD, the actual process for migration is still far from certain. First, it has to be ascertained whether banks have the capacity to process large quantities of SEPA payments, in particular SDD, whose volume in the euro area is at present still well below 1% of total direct debits. Second, the awareness that SEPA affects not only corporates IT applications, but also their business processes and functional operations, still needs to filter through to the executive level. And third, software vendors have to engage more actively in SEPA to support banks and corporates in migration and testing. At the country level, the national SEPA fora need to monitor the progress of migration, particularly of those entities that generate large payment volumes. At the European level, a particular challenge will be to assess and coordinate the repercussions that different migration rates in different countries have across countries. Due to interdependencies, a slow migration in one country can have adverse effects on a country where migration proceeds more quickly. The ECB in close cooperation with the national central banks is currently investigating how to actively support pan-european transparency in the SEPA migration process. First, there are plans to make available the updated national migration plans in a central location (i.e. the ECB s website), possibly in a table format that would allow an easy comparison of the situation in the various countries. Second, we are also investigating what are the best tools for monitoring migration at the pan-european level. Finally, I expect that the other SEPA Council members will also live up to their commitment to support SEPA migration, for example through timely and appropriate communication activities within their national and European constituencies. Dessert: looking forward EU and global agendas While no meal can be considered complete without a dessert, dietary requirements may call for a light dessert (or no dessert at all). That is why I would like to look at issues that will 4
gain more and more attention in the future. The Eurosystem s main priorities in addition to the SEPA integration process concern cards and payment innovation, with security being an overarching issue. These issues are also on the European Commission s agenda, as well as on the authorities agenda at global level. Central banks of developed and emerging countries brought together in the BIS Committee on Payment and Settlement Systems (CPSS) are about to publish a joint report on innovation in retail payments. It is interesting to note that although the CPSS report and the European Commission s Green Paper serve different purposes one being of a more descriptive nature, the other being a consultative document that may be followed up by legislative action they show a fundamental convergence of interests and objectives. The diffusion of innovative services relating to payments has both geographical and sectoral implications. The geographical implications are that, at present, merchants and consumers in Europe face a fragmented market, since most of the innovative solutions only work at the regional level, or even only at the bank level. At the same time, it can be observed that international solutions with roots outside Europe are entering the European internet payment market. The sectoral implications are that innovative services relating to payments are often provided outside the banking industry by licensed and non-licensed entities. The current legal and regulatory framework does not consistently meet the challenges that arise relating to access to payment accounts required by those entities. For example, non-bank providers offering overlay services in various EU countries are not currently considered to fall under the Payment Services Directive (PSD) and are thus not regulated or supervised. It is important that the current legal vacuum will be addressed in the revision of the PSD. Against this framework, I feel that there is a genuine need for adequate Europe-wide solutions to provide secure, efficient and user-friendly internet and mobile payment services. In order to satisfy merchants and consumers requirements for internet and mobile payment solutions, it is necessary to strike a healthy balance between efficiency and security. In this respect, public authorities may be required to provide appropriate guidance and legislation. Through its oversight function, the Eurosystem aims to ensure the safety and efficiency of the overall market infrastructure, e.g. by creating a minimum common threshold for security. In 5
2010, the Eurosystem facilitated the creation of the European Forum on the security of retail payments (SecuRe Pay), a voluntary cooperation between EU overseers and supervisors. SecuRe Pay s goal is to facilitate common knowledge and understanding of the issues at stake in the field of the security of retail payments. SecuRe Pay prepared a set of recommendations on the security of internet payments. And a public consultation on these recommendations was launched on 20 April 2012. Once finally approved, these security recommendations will be enforced by the overseers and supervisors of Europe, aiming at creating a harmonised approach to internet payment security and at ensuring the integrity of these internet payments. Any legislative support would be welcome given the relevance of the issue. In this respect, I would like to thank Ugo Bechis for underlining the possibility of including SecuRe Pay recommendations in legislation. So we can conclude that we have well-established initiatives in areas that are also deemed important at global level. On the other hand, the global agenda gives more emphasis than the European one to other issues concerning for example financial inclusions and remittances. Shall we do more? Is financial inclusion also an important issue for Europe? Do we need a SEPA-type project for remittances? These are questions we may wish to think about when setting priorities for a future agenda. Conclusion It is now time to go for lunch, so let me just briefly summarise my main points. First, the integration of retail payment systems remains an important public objective. Second, the actual migration process to SCT and SDD requires both analytical and practical support from all stakeholders involved to go ahead as planned. Third, in parallel, new challenges in the field of innovation need to be tackled. Given the necessity to strike the right balance between efficiency and security, public authorities have a responsibility to provide appropriate guidance, including legislation, if needed. As I already mentioned, increased efficiency in payments may increase social welfare and free up time and resources, benefiting not only individuals and businesses, but also society as a whole. That is why we should continue to work together with unabated commitment and enthusiasm. Thank you very much for your attention! 6