PSR readiness: five things EU PSPs should start doing today

With PSD3 and the revised PSR nearing finalisation, fraud and compliance leaders across Europe face a clear choice: wait for enforcement, or act now to build a faster, smarter, and more collaborative fraud response framework. Those who move early will not only reduce exposure and streamline reimbursement—they’ll gain a competitive advantage in customer trust and operational maturity.

1. Reframe reimbursement as a fraud prevention accelerator

Too often, reimbursement is viewed as a compliance cost. In reality, it’s a catalyst for investment in proactive fraud detection. The UK’s experience shows that shared liability and tighter timelines force institutions to invest in upstream controls—beneficiary risk scoring, behavioral analytics, and intelligent orchestration across teams.

EU PSPs should use the PSD3 window to shift fraud prevention from a defensive cost center to a strategic lever. Early investment reduces not just claims, but time spent on investigations and dispute resolution. It’s not just about paying faster—it’s about stopping fraud before it starts.

2. Build for five-day resolution—even if it’s not mandated (yet)

The draft EU regulation doesn’t fix reimbursement within five business days. But don’t let that fool you. The UK’s “five-day rule” is already shaping expectations across borders.

Consumers, regulators, and industry watchdogs increasingly view five-day reimbursement as a minimum benchmark. Even if the language remains “without undue delay,” the reputational bar has moved.

To meet this, institutions must start integrating their fraud detection and claim processing systems today. That means collapsing handoffs between risk, compliance, and customer ops—and supporting decision-making with better data, shared in real time.

3. Invest in cross-PSP collaboration infrastructure

Fraud doesn’t stop at institutional boundaries. Yet most institutions still work with an internal view—limited to their customer data, device logs, and transaction history.

PSD3 is a wake-up call. It’s time to build secure, real-time channels for cross-institutional fraud intelligence, where risk signals can be shared without violating GDPR or exposing sensitive data. This means moving beyond point-to-point alerts and embracing frameworks that allow real-time signal orchestration across the ecosystem.

Secure data collaboration platforms—those that enforce data policies, preserve privacy, and operate on encrypted inputs—are becoming essential. They unlock earlier detection of mules, synthetic identities, and high-risk recipients by enabling intelligence without exposure.

4. Align internal stakeholders before regulation forces it

Reimbursement isn’t just a fraud team problem. It touches compliance, customer service, product, operations, and finance. Many institutions will find themselves scrambling unless they start aligning now—on workflows, accountability, and investment priorities.

Create cross-functional task forces with clear mandates:

• Map reimbursement scenarios end-to-end

• Stress test internal response times

• Evaluate current gaps in beneficiary intelligence, collaboration tooling, and signal ingestion

• Define escalation pathways with legal, privacy, and fraud ops involved from the start

• Waiting for final texts will only shorten the time you have to operationalise.

  
  

5. Treat PSD3 as a chance to lead, not just comply

Institutions that treat PSD3 as a regulatory hurdle will build the bare minimum—and stay exposed to fraud, inefficiency, and reputational damage. Those who see it as a transformation opportunity will emerge with streamlined operations, stronger customer trust, and more resilient fraud defenses.

The financial institutions that will win in this new era are those that build interoperable fraud infrastructure, not just internal controls. They’ll collaborate without compromising data, prevent fraud before reimbursement becomes necessary, and turn compliance into competitive advantage.

Final thought

The PSD3/PSR package marks a turning point in Europe’s approach to payment fraud. The regulatory direction is clear: faster reimbursements, shared responsibility, and smarter collaboration. But regulation alone won’t deliver fraud resilience. It’s up to institutions to design systems that meet this new standard—safely, securely, and at scale.

For those who start now, the reward is more than compliance. It’s a foundation for leadership in an increasingly connected, real-time financial world.