EUU, Alm.del - 2017-18 - Bilag 85: Notat og høringssvar på Kommissionens høring om gennemsigtighed og gebyrer på grænseoverskridende betalinger

Europaudvalget 2017-18
EUU Alm.del Bilag 85
Offentligt

Directorate-General for Financial Stability, Financial Services and Capital

Markets Union

European Commission

Rue de Spa 2

1000 Brussels

MINISTER FOR INDUSTRY,

BUSINESS AND FINANCIAL

AFFAIRS

30 October 2017

Response to the

Commission’s public consultation

on Transparency

and Fees in Cross-Border Transactions in the EU

Thank you for the opportunity to respond to the Commission’s Consulta-

tion on Transparency and Fees in Cross-Border Transactions in the EU.

Further integration and development of the Single Market in the financial

services area, including the aim of creating an integrated market for pay-

ments in the EU, is an objective Denmark fully share. We also strongly

support the European REFIT-program with the aim of simplifying legisla-

tion and reducing administrative burdens.

In general, we support reducing fees on transaction services for both con-

sumers and businesses. Low and reasonable prices on cross-border trans-

actions could enable more trade and activity across the EU, supporting

growth and creation of jobs as well as investment opportunities.

Possible initiatives to address these objectives should be based on a thor-

ough analysis of the impact in line with the principles of the Better Regu-

lation agenda. This includes analysis of benefits and costs for consumers,

businesses and financial institutions; potential costs associated with legis-

lative compliance; and the possible impact on other banking services if

real costs in transaction services cannot be covered. Generally, less intru-

sive alternatives to regulation should be part of such an analysis.

Further, financial technology (Fintech) has developed significantly during

the past few years and many new services imply easier ways of conduct-

ing transfers or even establish alternatives to already existing transaction

services. We should be conscious not to

“pick

winners”, nor in any way

be biased towards specific solutions or services nor implement legislation

which might have that effect.

The introduction of PSD2 should also be taken into account as payments

and transactions services are closely interlinked. The payment area regu-

lated in PSD2 taps into both Fintech and transaction services. Thus, this

recently introduced regulation could very well have an effect on cross-

border transactions and the cost associated with such transactions. There-

MINISTRY OF INDUSTRY,

BUSINESS AND FINANCIAL

AFFAIRS

Slotsholmsgade 10-12

1015 Copenhagen K

Denmark

Tlf.

+45 33 92 33 50

Fax.

+45 33 12 37 78

CVR-nr. 10092485

EAN nr. 5798000026001

[email protected]

EUU, Alm.del - 2017-18 - Bilag 85: Notat og høringssvar på Kommissionens høring om gennemsigtighed og gebyrer på grænseoverskridende betalinger

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fore, it might be appropriate to await the effect that these developments in

regulation and technology might have on transactions and the associated

fees before new regulation is considered.

It should also be kept in mind that fees on cross-border transactions, in-

cluding from Denmark to other Member States, are already declining.

This development indicates market dynamics leading toward the cheapest

and most efficient way of doing transactions.

Therefore, we would suggest that the Commission thoroughly investigates

new developments in the market as well as societal costs, benefits and

experience from past regulation (this could also include experiences from

other areas such as the roaming regulation) before new legislation is pro-

posed.

At the moment we are not convinced of the merits of including the Danish

Krone in the regulation, and following this consideration Denmark has

chosen not to use this discretion for non-euro Member States in the cur-

rent regulation. However, if the Commissions analysis provides clear and

sufficient grounds for including the Danish Krone and other non-euro

currencies in the regulation, we would be open to look further into such

an initiative in order to meet the objective of securing low and reasonable

prices for cross-border transactions. In line with the Better Regulation

principles, the analysis should also explore alternative approaches and

ensure that possible initiatives leave room for new innovation and market

dynamics.

I remain at your disposal for any comments or questions that you might

have, and I look forward to a constructive dialogue on how best to

achieve the objectives of well-functioning and integrated markets to the

benefit of consumers and business.

Yours sincerely,

Brian Mikkelsen

Minister for Industry, Business and Financial Affairs