The exclusion for commercial agents has historically held an ambiguous position within EU payments regulation. Originally intended as a limited exception for legitimate sales intermediaries, it has increasingly been used in arrangements that regulators perceive as a means of avoiding licensing requirements. This regulatory tension is not new, but it is now being directly addressed through the forthcoming Payment Services Regulation (PSR), following the broader reforms introduced under PSD3.
The commercial agent exclusion has long occupied an uneasy position in EU payments regulation. Conceived as a narrow carve-out for genuine sales intermediaries, it has increasingly become a vehicle for structures that regulators view as circumventing licensing altogether. This tension predates PSD3 and is now being addressed head-on through the forthcoming Payment Services Regulation (PSR).
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