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ARTICLE · 13 APRIL 2026

PSD3 And PSR – Implementation And Implications For The Swiss FinTech Industry

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As a third country, Switzerland is obliged neither by a bilateral nor by a multilateral agreement to transpose EU secondary law in the field of financial services. The bilateral agreements between Switzerland and the EU do not contain a market access agreement for financial services. PSD3 and PSR will therefore have no direct effect in Switzerland. Swiss payment service providers are primarily governed by Swiss law

SwitzerlandTechnology
Peter Ruggle
Peter Ruggle

A Legal Assessment from a Swiss Perspective

Abstract

With the legislative package presented by the European Commission in June 2023 on the Payment Services Directive 3 (PSD3) and the Payment Services Regulation (PSR), EU payment services regulation is facing its most comprehensive reform since 2015. The proposals were adopted by the European Parliament at first reading in April 2024; trilogue negotiations are underway, with application expected from 2026/2027. For Switzerland, which as a third country is under no obligation to transpose these rules, the question arises as to the extent to which the new regulations will have a legal, practical and economic impact on the domestic financial centre and, in particular, on the FinTech industry. This article analyses the key innovations of PSD3/PSR, places them within the Swiss legal framework, and identifies strategic options for Swiss payment service providers, banks and FinTechs.

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