Through the spring, some commentary assumed that PSD3 and the Payment Services Regulation would reach the Official Journal by early summer, with September as the pessimistic case; Freshfields' May briefing anticipated June or July, slipping to September at worst. It is now September and, at time of pixel, the Parliament's procedure files for both instruments,2023/0210(COD) for the PSR and 2023/0209(COD) for PSD3, carry an indicative plenary date of 14 December 2026.
This note is about where those months went, and what the files actually say.
The procedure, briefly
The package is following the early second reading route, which produces a status line that looks backwards if you have not met it before. The Permanent Representatives Committee endorsed the final compromise texts on 22 April, the Council made them public on 23 April, and Parliament's ECON committee approved the agreed texts on 5 May. Both procedure files currently read "Awaiting Council's 1st reading position".
That is not the process reversing. Under this route, the Council must formally adopt a first-reading position incorporating the agreed text; Parliament is then expected to approve that position at second reading without amendment, at which point the acts are adopted. The presidents sign, the Official Journal publishes, and both instruments enter into force twenty days later. The political bargain was struck in November 2025 and the texts were stabilised in April and May 2026. What remains is principally formal adoption work rather than renegotiation, although adoption is not legally automatic: Parliament retains the power to amend or reject at second reading, and the expectation is only that it will not use it.
Why the machinery takes this long
One necessary, and likely substantial, part of the remaining work is legal-linguistic revision. Before the Council adopts its position, lawyer-linguists finalise the base text and make it consistent across all twenty-four equally authentic language versions. The PSR compromise document alone runs to 431 pages, and its drafting carries visible scars: bracketed date placeholders in several malformed variants, a repeated "data of application" typo, and a missing closing bracket in the clause repealing the e-money directive. Each defect must be resolved in the base text and the correction carried into every language version.
There is a useful, though imperfect, comparator. PSD2 followed a first-reading agreement rather than the present route. Its informal political agreement came in May 2015; Parliament adopted its first-reading position on 8 October; the Council formally adopted the act on 16 November; it was signed on 25 November and published in the Official Journal on 23 December. Nearly eight months from agreement to publication, for a shorter text and a single instrument. The present package reached political agreement on 27 November 2025 and, nine months later, the Council has yet to adopt its first-reading position.
What it means for planning
If the December date holds and publication follows around the turn of the year, entry into force would probably fall in January or February 2027. On that illustrative assumption, the twenty-one month general application date lands in October or November 2028, and PSR Article 50's extension of the matching rules, with Article 57's associated liability rule, applies in April or May 2029. These are scenarios, not forecasts: every date depends on an indicative parliamentary timetable and the eventual publication date.
For firms planning on annual budget cycles, that makes this a 2027 mobilisation and 2028 delivery programme, with the Articles 50 and 57 strand extending into 2029. Budgets scoped this autumn for the 2027 cycle are the ones that will fund the work, and they should be scoped against the compromise-text numbers rather than the proposal-era ones. The numbers themselves, and the provisions that apply from entry into force rather than waiting for the general date, are in the previous essay.
The paymentslaw.eu corpus reflects the Council compromise texts, and its monitoring routine checks the procedure files every working morning. When the Official Journal versions appear, the corpus and this site will say so the same week.