Transaction Intelligence is Matt Berryman's independent writing on 3-D Secure and the EU regulation that governs payments authentication: essays that read the specification and the legislation each on its own terms, put them together where they meet, cite the field and the provision, and say what they mean for the people who have to implement them.
Most of what gets written about 3-D Secure and payments regulation is either marketing or a summary of someone else's summary. By the time a provision or a field reaches a briefing note it has usually passed through three hands, and the errors compound quietly: a date repeated from an earlier draft, a carve-out that no longer exists, an article number that moved in trilogue, a value quoted from the wrong version of the specification.
I work from the primary texts: the legislation, the EMV 3-D Secure specification and the scheme rules that are public, alongside the supervisory notices, the enforcement decisions and the standards documents. Where a claim rests on secondary commentary, I say so. Where the primary text is ambiguous, I say that too, and inference is labelled as inference. Where something here contradicts the prevailing view, the citation is in the piece and you can check it.
That makes for a narrower output than a trade publication, and a slower one.
What it covers
3-D Secure comes first: the protocol as it is specified and as it is run, the scheme rules on authentication and liability, and strong customer authentication under PSD2 and the RTS today and, once adopted, the PSR. The regulation is where that extends: PSD2, PSD3 and the PSR wherever they bear on authentication, authorisation, liability and fraud. Agentic payments, passkeys and machine-readable law come in where they meet the text.
The older essays on behaviour, design, banking technology and AI stay published, and I still wander outside the territory now and then.
Who writes it
Matt Berryman. Payment security executive, specialist in authentication, 3-D Secure and regulatory compliance, and a former startup founder, with fifteen years in payments authentication, fraud risk and pre-sales across issuers, schemes and vendors.
I also build and maintain two reference sites:
- EU Payments Law (paymentslaw.eu), the working copy of EU payments legislation, with the source, version and legal status beside every provision, and
- 3dsspec.com, a reference for the EMV 3-D Secure messages, fields and flows.
Both exist because I needed them and could not find them.
A personal site, written under Matt Berryman's own name and not on behalf of any employer, client or vendor, from the public record only. Nothing here is legal advice.
The newsletter
An essay every second Tuesday, by email or RSS. Free. No sponsorships, no guest posts, no PR placements. One click unsubscribes, and it works the first time.
In the weeks between, the shorter arguments I make on LinkedIn are kept in Out of band, with their sources and the date I made them. Those are not sent by email.
Corrections
When a reading here turns out to be wrong, I correct it in the open, with a dated note in the piece, never a silent edit. If you spot one, email hello@transactionintelligence.net.
Contact
- Email: hello@transactionintelligence.net
- LinkedIn: @mattberryman