PSD3 Readiness
The European Commission's PSD3 proposal revises transaction reporting timelines, tightens open banking compliance requirements, and is expected to trigger substantial schema updates across all major NCAs. Get ahead of it now.
Key PSD3 reporting changes vs current PSD2
Proposed changes from the EC draft and EBA consultation papers — subject to trilogue finalization. Status reflects our reading of current published material.
| Reporting area | Current PSD2 obligation | PSD3 proposed change | Impact |
|---|---|---|---|
| Fraud incident reporting | Annual aggregate, calendar year | Semi-annual, additional real-time threshold triggers | HIGH |
| Transaction data formats | PAIN.001 / PAIN.002 ISO 20022 | Aligned to ISO 20022 2025 harmonized namespace | HIGH |
| Open banking API incidents | Not separately required | Separate API downtime reporting channel to NCAs | NEW |
| Intragroup transactions | Full reporting required | Simplified intragroup exemption thresholds | MEDIUM |
| NCA submission portal | Per-NCA submission (no common API) | EBA central gateway proposed (not confirmed) | TBC |
Source: EC PSD3 legislative proposal COM(2023)366; EBA consultation EBA/CP/2024/11. Content is informational only — not legal advice.
How Fynrex handles the PSD3 transition
Schema registry watch
When NCAs publish PSD3-aligned schema updates, Fynrex detects them within 24 hours. You're notified before your submission window — not after a rejection.
Version-pinned generation
Each generated report package is pinned to the exact schema version active at submission time. Transitioning from PSD2 to PSD3 schemas is a tracked migration, not a manual cut-over.
Multi-NCA parallel coverage
If PSD3 NCAs update schemas on different timelines (expected), Fynrex tracks each NCA's transition date independently. You don't need to manage a migration calendar per regulator.
Retroactive audit integrity
PSD3 examiners will likely review PSD2-era submissions. The immutable audit trail preserves the schema version that was active when each historical submission was made.