PSD3 / PSR Readiness Checklist: Your Compliance Guide

Alejandro Martínez · 2026-06-23

### What Is PSD3 and Why Should You Care? The Payment Services Directive 3 (PSD3) is the next big regulatory shift for payment providers in Europe. It builds on PSD2 but tightens the rules. If your firm handles payments in the EU, you need to understand what's coming. This checklist is based on the Malta Financial Services Authority's (MFSA) DEAR CEO letter. It outlines minimum expectations for authorized persons. The goal is to help you prepare before the deadline hits. ### Key Areas to Focus On Your compliance team should start with these core areas: - **Governance and oversight**: Make sure your board understands PSD3 requirements. Assign clear responsibilities. - **Risk management**: Update your risk frameworks. PSD3 demands stronger controls around fraud and data security. - **Customer protection**: Review your dispute resolution processes. New rules mean faster refunds for unauthorized transactions. - **Reporting obligations**: Expect more frequent and detailed reporting to regulators. ### How to Use This Checklist Think of this as a starting point. Every firm is different. Your specific obligations depend on your license type and business model. > "Preparation is the key to smooth compliance. Start early, involve your legal team, and don't wait for the deadline." ### Common Pitfalls to Avoid Many firms underestimate the time needed to update their systems. Here are mistakes to watch for: - Ignoring legacy IT infrastructure. Old systems may not handle new data requirements. - Assuming PSD3 is just an extension of PSD2. It's not. The changes are significant. - Failing to train staff. Everyone from customer service to IT needs to know the new rules. ### Next Steps for Your Team Start with a gap analysis. Compare your current practices against the MFSA expectations. Then create a project plan with clear milestones. If your compliance team requires legal support and guidance on PSD3 compliance, reach out to qualified experts. The earlier you act, the smoother the transition. ### Final Thoughts PSD3 isn't just a regulatory burden. It's an opportunity to strengthen your operations and build trust with customers. Use this checklist to stay ahead. This document is prepared based on the MFSA publication of the DEAR CEO letter. It is circulated for clear information purposes only.