Regulation guide
What is the Payment Services Directive?
PSD2 is EU payments law, not anti-money laundering law, and it is being replaced. Here is what it covers, when it reaches an Australian business, and what Australia does instead.
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PSD2 in context
The Payment Services Directive is European Union law governing how payment services are authorised, supervised and secured. The current version, commonly called PSD2, is Directive (EU) 2015/2366. It replaced the original 2007 directive, and most of its rules have applied since January 2018, with the requirements on strong customer authentication following in September 2019.
It reaches this reference for one reason: people arrive asking whether it applies to them. Usually it does not. PSD2 binds payment service providers operating within the EU, and an Australian business is brought into scope by where it operates rather than by where its customers live. If you provide designated services in Australia, your obligations come from the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 and AUSTRAC, not from Brussels.
What PSD2 actually regulates
PSD2 is a conduct, prudential and security regime. It sets out who needs authorisation to provide payment services, what capital and safeguarding requirements they carry, what must be disclosed to customers about charges and execution times, how liability for unauthorised transactions is allocated, and how payments must be authenticated. It is not an anti-money laundering instrument, and conflating the two is the most common misreading of it.
Its best-known effect is open banking. PSD2 requires account-servicing providers, in practice banks, to let licensed third parties initiate payments and access account information when the customer instructs it. That created two provider categories that had not previously existed in EU law: payment initiation service providers, which move money on the customer's instruction without holding it, and account information service providers, which read account data to deliver services such as aggregation or affordability assessment.
Where the AML obligations really come from
Firms authorised under PSD2 do carry substantial AML duties, but those duties are imposed elsewhere. Payment institutions and electronic money institutions are obliged entities under the EU's anti-money laundering framework, which is being consolidated: the Anti-Money Laundering Regulation, Regulation (EU) 2024/1624, was adopted in 2024 and applies directly across member states from 10 July 2027, supervised alongside the new EU Anti-Money Laundering Authority. Customer due diligence, beneficial ownership and reporting expectations for an EU payment institution are set there, not in PSD2.
The distinction has a practical consequence. Strong Customer Authentication is often presented as an AML control. It is a fraud and payment-security requirement. It produces evidence that is genuinely useful when investigating suspicious activity, and it does nothing to discharge a customer due diligence obligation.
PSD2 is being replaced
The framework is mid-transition, which is worth knowing before relying on any summary of it, including this one. The European Commission proposed a replacement package in June 2023: a third Payment Services Directive covering authorisation, prudential supervision and safeguarding, and a directly applicable Payment Services Regulation covering conduct of business. Together they repeal and replace PSD2 and the second Electronic Money Directive, merging the payment services and e-money regimes into a single framework.
Parliament and Council reached provisional agreement in November 2025, the Council published final compromise texts in April 2026, and the Parliament's economic affairs committee approved the agreed text in May 2026. As at September 2026 formal adoption and publication were still outstanding. On the agreed texts both instruments apply 21 months after entry into force, with mandatory verification of payee arriving at 27 months and a transitional period for existing e-money institutions. Anyone with EU payments exposure should be planning against PSD3 and the PSR rather than against PSD2 alone.
The Australian equivalents
Australia has no single PSD2 analogue. The same territory is covered by two separate reform tracks.
Open banking sits outside payments law entirely, in the Consumer Data Right under Part IVD of the Competition and Consumer Act 2010. It is a consumer data access regime that happens to have been rolled out through banking first, rather than a payments directive that happens to mandate data access.
Payment provider regulation is being rebuilt through Treasury's payments system modernisation programme. The direction of travel is an activity-based framework in which providers performing defined payment functions require an Australian Financial Services Licence, with ASIC responsible for conduct, APRA for prudential regulation of major stored-value facilities and designated providers, and the Reserve Bank able to authorise industry standard-setting. The payment functions proposed include stored-value facilities, payment stablecoins, payment instruments, payment initiation services, payment facilitation services, payment technology and enablement services, and cross-border transfer services. Treasury released tranche 1 draft legislation for consultation in March 2026 and has signalled further tranches, so the detail is still moving.
What this means if you are a reporting entity
For most Australian reporting entities, PSD2 is context rather than obligation. The point at which it stops being academic is cross-border payments, and groups operating on both sides. International funds transfers and remittance are designated services under the AML/CTF Act, so they are captured here irrespective of what the receiving jurisdiction requires. A group operating in both Australia and the EU faces two regimes with similar intent and different drafting, and cannot assume one control set satisfies both.
If you are working out which regime actually binds you, that is a scoping question worth answering before you build controls around it. Australian AML/CTF scope is something we can help with directly. EU authorisation questions need EU-qualified advice.
Four things PSD2 is, and is not
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A conduct and security regime, not an AML one
PSD2 governs authorisation, consumer protection, payment security and access to accounts. AML duties for the firms it authorises come from the EU's separate AML framework.
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Open banking through mandated access
Account-servicing providers must let licensed third parties initiate payments and read account data on the customer's instruction, which created the AISP and PISP categories.
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Strong Customer Authentication
Two independent factors for most electronic payments, applicable since September 2019. A fraud control, and the reason SCA is often mistaken for an AML requirement.
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Being replaced by PSD3 and the PSR
A recast directive plus a directly applicable regulation will absorb PSD2 and the E-Money Directive into one framework, phased in after formal adoption.
Common questions
Does PSD2 apply to Australian businesses?
Not by virtue of operating in Australia. PSD2 is an EU directive implemented through member state law, and it binds payment service providers offering services within the EU. An Australian business is drawn in by where it operates, not where its customers happen to live: establishing an EU entity, seeking authorisation as a payment or e-money institution in a member state, or acquiring one. Serving an occasional EU-resident customer from Australia does not itself create PSD2 obligations, though it can raise other questions such as GDPR. If you think you may be in scope, that is a question for EU-qualified advisers.
Is PSD2 an anti-money laundering law?
No, and the distinction matters. PSD2 covers authorisation, prudential requirements, conduct, transparency and payment security. AML and counter-terrorism financing obligations for the firms it authorises sit in the EU's AML framework, which is why payment institutions and e-money institutions are treated as obliged entities there rather than under PSD2. Strong Customer Authentication is frequently described as an AML control; it is a fraud and payment-security control that happens to produce useful evidence for AML purposes.
What is replacing PSD2?
Two instruments. A third Payment Services Directive (PSD3) covering authorisation, prudential supervision and safeguarding, and a directly applicable Payment Services Regulation (PSR) covering conduct of business. Together they replace PSD2 and the second E-Money Directive, merging the payment services and e-money regimes. The European Commission proposed both in June 2023, Parliament and Council reached provisional agreement in November 2025, and the Council published final compromise texts in April 2026. As at September 2026 formal adoption was still outstanding. On the agreed texts, both apply 21 months after entry into force, with mandatory verification of payee at 27 months.
Does Australia have an equivalent to PSD2?
Not a single one, but the same ground is covered by two separate reforms. Open banking runs through the Consumer Data Right in Part IVD of the Competition and Consumer Act 2010, rather than through payments law. Payment provider licensing is being rebuilt under Treasury's payments system modernisation programme, which moves to an activity-based framework requiring an Australian Financial Services Licence for defined payment functions. Treasury released tranche 1 draft legislation for consultation in March 2026.
What is Strong Customer Authentication?
Authentication using at least two independent factors drawn from knowledge (a password or PIN), possession (a device or token) and inherence (a biometric), where compromising one does not compromise the others. It has applied to most electronic payments in the EU since September 2019 under the regulatory technical standards made under PSD2, subject to exemptions for low-value and low-risk transactions.
Where does this actually touch an Australian reporting entity?
Usually at cross-border payments. Your AML/CTF obligations come from the designated services you provide under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006, and international funds transfers and remittance are captured there regardless of what the receiving jurisdiction requires. The practical overlap is that a group operating both in Australia and the EU must satisfy two regimes whose customer due diligence, record keeping and reporting expectations are similar in intent but drafted differently, and cannot assume one set of controls discharges both.