This note compares the Commission's June 2023 proposal, COM(2023) 367, with the Council's April 2026 compromise, ST 8221/26, using the comparison in paymentslaw.eu. The compromise is a draft. The comparison establishes differences between these two texts, not changes to applicable law, and nothing here says who moved a change or when.
Article 23 governs how a framework contract ends. Between the proposal and the compromise, two figures changed: the period during which a provider may still charge you for terminating fell from six months to three, and the minimum notice a provider must give to end an indefinite contract, where the contract permits that route, rose from two months to three. The comparison scores the article at 99% similarity and classifies it as 'limited' textual change, which is fair, since two figures moved in seven paragraphs. A plan that carried the proposal's notice period forward would still say two months where the April draft requires at least three.
I ran the comparison across the whole regulation this week and then read the articles in that limited-change category. The four in this note are my selection, chosen because each carries a changed obligation, and each shows why the amount of text that changed tells you nothing about what your plan needs.
The other three
Article 63(2) changes one figure. The period in which a provider must refund, or justify refusing a refund under Article 62, moves from ten business days to fifteen. The eight-week period for making the request is unchanged, and so is the sentence that removes the right to refuse in the case identified by Article 62(1), fourth subparagraph. That sentence is the trap. The reference survived, and the provision it points to did not: in the proposal the unconditional refund right covered authorised transactions initiated by a payee, including direct debits, and in the compromise it covers direct debits. Both versions stay subject to paragraph 3's contractual exclusion, and what that means for any particular transaction depends on the scope provisions below. What I can tell you is that reading Article 63 on its own would never have shown it.
Article 68(2) raises an agreed execution-time ceiling from four business days to five. Its reach is narrow and worth stating in full: an intra-Union transaction outside the categories in paragraph 1, where you and your provider have agreed a period longer than Article 69 provides, counted from receipt under Article 64. That is the whole of it. It is not a five-day rule for anything else, and Article 73 stays outside what the parties can disapply.
Article 94(2) deletes five words. The compromise removes "make every possible effort to" from the duty to reply to a complaint and leaves everything around it in place: the fifteen-business-day reply, the holding reply for reasons beyond the provider's control, the thirty-five-business-day longstop, and the rule that more advantageous national provisions prevail. The qualifier moved. The clock did not.
What this says about your plan
The word-level comparison shows every one of these amendments plainly. The risk arrives when someone turns the comparison into a summary and drops a condition, reads a minimum as a maximum, or treats an unchanged reference as proof of an unchanged rule. I include myself in that; two of those three happened while this note was being drafted, and review caught them.
So start from the obligations your plan relies on, and use the comparison to check them. Open each article in both versions and check the figures and the qualifiers. Follow the references that determine an obligation or its exceptions. Read the definitions, since a changed term can alter the reach of an article whose own words did not move, though whether it does is a question to answer rather than a conclusion to assume.
Then check whom the rule reaches. Article 4(1) lets the parties disapply Title II, in whole or in part, where the user is not a consumer, which takes in Article 23. Article 27 permits agreed derogation from Articles 62 and 63 on the same footing. Both let Member States treat microenterprises as consumers. Those questions belong in the assessment before anyone decides a process has to change.
Which brings me to the distinction I would most like you to keep. For a refund request covered by Article 63, an internal target of ten business days does not need lengthening because the draft's ceiling has become fifteen. A document that describes ten as the maximum under the April draft does need correcting. One is the sentence that records the legal requirement, the other is the commitment your business chose to make, and the comparison only ever speaks to the first.
If you connected the corpus last week, each comparison above is one request away, with both texts in front of you. I would sooner you checked my four than took them on trust, because this site sits under the same test it applies to everyone else.