ECB, EBA and EEA authorities sign an MoU on non-bank access to central-bank payment systems

Victoria Shinder17 October 2026, 09:072 min read

The European Central Bank, the European Banking Authority and national supervisory authorities and national central banks across the European Economic Area signed a Memorandum of Understanding, dated 16 October 2026, on sharing information "in support of the access of non-bank payment service providers" (NB-PSPs) to central-bank-operated payment systems. It is not a new rule but an operational framework built on existing law — chiefly the revised Payment Services Directive (PSD2) and ECB Decision (EU) 2025/222 of 27 January 2025 on NB-PSP access to Eurosystem systems and central-bank accounts.

Why it exists. An EU instructions-pending regulation inserted conditions into PSD2 (Article 35a) that NB-PSPs must meet to participate in central-bank-operated payment systems. National central banks grant that access, but the compliance assessment and the authorisation of the provider sit with national supervisors. The MoU's recitals name the gap plainly: without a channel between the two, a provider whose authorisation has been suspended or withdrawn could keep accessing a payment system and executing transactions unlawfully, a risk to the smooth operation of payment and settlement and to broader financial stability.

What the MoU sets up. Article 1 lists three purposes: establish cooperation between national supervisory authorities (NSAs) and national central banks (NCBs) so NCBs can assess NB-PSPs' compliance with the access requirements, including PSD2 Article 35a, in a timely manner; set cross-border procedures so that, where the payment system is in a host Member State, that NCB notifies the home-Member-State NSA of the application and its decision; and harmonise the processes by specifying what information is shared, when and how. The recitals tie this to the Eurosystem's Treaty task (Article 127(2) TFEU) of promoting the smooth operation of payment systems, and cover providers already participating at the time of signing as well as new applicants.

The document is the signed framework among the EBA, the ECB and a long list of national supervisors and central banks; the detail — definitions, the exact information to be exchanged and the timing — is in its articles. For the euro area the practical effect is procedural: a single, harmonised way for supervisors and central banks to keep each other current on an NB-PSP's authorisation status as it seeks or holds access to central-bank payment rails.

Source: European Central Bank, "Memorandum of Understanding on the cooperation framework for information sharing… in support of the access of non-bank payment service providers" — https://www.ecb.europa.eu//pub/pdf/other/ecb.2026-10-16_MoU.en.pdf