Author

Matt Berryman

Payment security executive. Specialist in authentication, 3-D Secure and regulatory compliance. Former startup founder. Builder of EU Payments Law and 3dsspec.com.

https://www.linkedin.com/in/mattberryman/

  1. № 1 · 02 Nov
    Out of band Out of band

    Two EU sites, two clocks

    Parliament’s Legislative Observatory still says the Council’s first-reading position on PSD3 and the PSR is awaited. The Council adopted both on 29 October, 27 votes to 0. Both pages are right: they keep different clocks.

    1 min read
  2. № 2 · 27 Oct
    Out of band Out of band

    The fraud report is a third ledger

    A 3DS liability shift moves the fraud loss and blocks the fraud dispute. It does not stop the issuer’s fraud report, and Visa’s VAMP ratio counts fraud reports as well as disputes.

    2 min read
  3. № 3 · 20 Oct
    Regulatory

    The monitoring you have to prove

    A passed 3DS challenge proves the customer answered it, and under the PSR compromise text that would not be enough. An issuer that cannot show the customer its monitoring ran would refund the payment, so what you assessed, and when, becomes the record that matters.

    5 min read
  4. № 4 · 13 Oct
    Authentication Out of band

    The human in the loop is already in the spec

    When an AI agent buys something, how does the cardholder's bank get the cardholder to say yes? The published EMV 3DS specification already has an answer: a 3RI request answered with a decoupled challenge. What is missing is support and settled law.

    2 min read
  5. № 5 · 06 Oct
    Regulatory

    Authorised to do what?

    Visa's rules make a cardholder responsible for an agent's purchase as if they initiated it. PSD2 asks whether they consented. A 2024 CJEU case on human proxies suggests what an issuer will have to prove, and the answer runs through the record of what the agent was told.

    5 min read
  6. № 6 · 29 Sep
    Regulatory Out of band

    Agent indicator or intent record?

    Six banks say any party holding a potential liability should be able to require authentication. In the EU that is the issuer, yet the published EMV 3DS specification has no field telling its ACS an agent is acting. Which signal should reach the ACS first?

    1 min read
  7. № 7 · 22 Sep
    Regulatory

    Reading a Compromise Text

    Four PSR articles with small textual changes and a changed obligation in each. A method for checking the obligations in your implementation plan against the April compromise, using the comparison and following its references.

    3 min read
  8. № 8 · 15 Sep
    Regulatory

    Give your AI the source

    Connect ChatGPT or Claude directly to paymentslaw.eu and check the sources behind an SCA answer. A free, read-only connection to 51 curated EU payments instruments, with provisions, source editions and citations you can open.

    2 min read
  9. № 9 · 08 Sep
    Regulatory

    SCA gets a promotion

    Strong customer authentication is being moved into a directly applicable regulation, not just amended. Your transition plan needs to separate what the text specifies, what waits on the EBA, and what it assumes about the handover. The law leaves that last part implicit.

    9 min read
  10. № 10 · 01 Sep
    Regulatory

    Where the payments package actually is

    A May forecast for summer publication has come and gone. The official record now points to December, and carries a status line that reads backwards until you know the procedure.

    3 min read
  11. № 11 · 25 Aug
    Regulatory

    Three numbers that no longer exist

    The PSD3 and PSR timetable has moved, but many summaries have not. The April 2026 compromise texts change the planning assumptions and contain two easily missed provisions that apply from entry into force.

    5 min read
  12. № 12 · 16 May
    Authentication

    When “something you are” becomes “something they can make”

    One in five biometric fraud attempts now involves a deepfake. The figure is striking on its own, but the more interesting story sits underneath it: inherence has quietly become the awkward leg of the SCA stool, and the trilogue text of the PSR is the first regulatory instrument to acknowledge it.

    3 min read