Article
Should The Commercial Agent Exclusion Be Treated As A Free Pass?
The commercial agent exclusion in EU payments regulation has evolved from a narrow carve-out for genuine sales intermediaries into a structure that regulators increasingly view as a means of circumventing licensing requirements. This regulatory tension, which predates PSD3, is now being directly addressed through the forthcoming Payment Services Regulation (PSR). How will these reforms reshape the landscape for payment service providers and commercial agents operating within the European Union?
MK Fintech Partners