IRELAND Trends and Developments Contributed by: Christopher Martin, Derek Hegarty and Nicola Munnelly, KPMG Law
Payment services and access to cash PSD3 and PSR The EU is currently in the process of review - ing and overhauling the existing payment ser - vices framework, with a particular focus on the increasingly digital nature of payments in the EU, as well as providing greater consistency in application and approach to the regulation of payment services across the EEA. The Third Payment Services Directive (PSD3) and the Pay - ment Services Regulation (PSR), which are likely to be adopted in 2025 and come into effect 18 months later, will build on and recast many of the rules currently set out in the Second Pay - ment Services Directive (PSD2). These will be implemented in the context of a broader retail payments strategy, including SEPA Instant and FiDAR. There are six key objectives of the reform: • combatting and mitigating payment fraud; • improved consumer rights; • levelling the playing field between banks and non-banks; • improved functioning of open banking; • improved availability of cash in shops through ATMs; and • strengthening harmonisations and enforce - ment. Key changes to the existing requirements under PSD2 will include the following. • Reform of the existing list of payment servic - es, including merging services enabling cash to be placed on and/or withdrawn from a pay - ment account, and the execution of payment transaction (both generally and covered by a line of credit), and the differentiating between the payment services of issuing payment
tration perspective (where certain AI Systems are provided by only a few providers) as well as a digital operational resilience perspective (ie, in accordance with DORA), also creates risks. The Central Bank is likely to be the competent authority for overseeing compliance with obliga - tions under the AI Act for financial institutions, as well as the interaction with the broader financial services legislation. As part of its own engagement on the use of AI, and aligned with Ireland’s National AI Strat - egy, the Central Bank last year announced a collaboration with the Insight Research Ireland Centre for Data Analytics at University of Limer - ick. This programme, which opens in 2025, will see the Central Bank funding a dedicated PhD programme in AI and data science to run for over six years. It will focus on research that builds public trust, improves policy outcomes and cul - tivates the next generation of AI talent, includ - ing through safer financial systems and better outcomes for consumers of financial services, as well as addressing issues such as responsible AI, financial crime, and cyber and climate risk. Whilst the use of AI Systems potentially offers significant benefits in terms of the provision of financial services, both customer-facing and back office, these will need to be effectively bal - anced against the potential risks to the business and its customers. Ireland, both nationally and within the Central Bank, looks to focus efforts on developing these products and solutions, and positioning Ireland as a centre of excellence for the development and implementation of AI solu - tions.
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