EUROPEAN COMMISSION
Brussels, 11.9.2025
COM(2025) 485 final
REPORT FROM THE COMMISSION
assembling specific payment account related data from Member States as required by Article 27 of the Directive 2014/92/EU of the European Parliament and of the Council on the comparability of fees related to payment accounts, payment account switching and access to payment accounts with basic features
CONTENTS
1. INTRODUCTION
2. COMPLIANCE BY PAYMENT SERVICE PROVIDERS WITH ARTICLES 4, 5 AND 6
3. COMPLIANCE BY MEMBER STATES WITH THE REQUIREMENTS TO ENSURE THE EXISTENCE OF COMPARISON WEBSITES PURSUANT TO ARTICLE 7
4. NUMBER OF PAYMENT ACCOUNTS THAT HAVE BEEN SWITCHED AND THE PROPORTION OF SWITCHING APPLICATIONS THAT HAVE BEEN REFUSED
5. NUMBER OF CREDIT INSTITUTIONS OFFERING PAYMENT ACCOUNTS WITH BASIC FEATURES, THE NUMBER OF SUCH ACCOUNTS THAT HAVE BEEN OPENED AND THE PROPORTION OF REFUSED APPLICATIONS FOR PAYMENT ACCOUNTS WITH BASIC FEATURES
6. CONCLUSION
1. INTRODUCTION
The Payment Accounts Directive (PAD) entered into force in September 2014. Member States had until 18 September 2016 to adopt and publish the laws, regulations and administrative provisions necessary to comply with PAD. Under Article 27 of PAD, the Commission is required to prepare a report providing the following information:
1.compliance by payment service providers with Articles 4, 5 and 6 of PAD;
2.compliance by Member States with the requirements to ensure the existence of comparison websites pursuant to Article 7 of PAD;
3.the number of payment accounts that have been switched and the proportion of applications for switching that have been refused;
4.the number of credit institutions offering payment accounts with basic features, the number of such accounts that have been opened and the proportion of applications for payment accounts with basic features that have been refused.
As set out in Article 27, the report is based solely on data provided by the Member States. However, the data contains certain gaps (e.g. when information was not available in a Member State). Data collection methodologies and sources may also have been different across Member States, which may make comparisons and assessment difficult.
This is the second report based on Article 27 of PAD, covering information relating to 2022 and 2023 1 . It has been prepared on the basis of a questionnaire that was discussed and agreed with government representatives from the 27 EU Member States.
2.COMPLIANCE BY PAYMENT SERVICE PROVIDERS WITH ARTICLES 4, 5 AND 6
Chapter II of PAD introduces rules to ensure that payment service providers make available clear and transparent information about fees related to payment accounts. Its two primary goals, as stated in the PAD recitals, are to (i) strengthen the internal market for retail banking; and (ii) empower consumers to effectively compare offers and make informed choices.
The first step in achieving these goals is to establish a standardised terminology, as outlined in Article 3 of PAD. To accomplish this, Member States are equipped with a list of the most common fee-based services linked to a payment account, developed through a comprehensive and step-by-step approach. This standardised terminology is laid down in a Delegated Regulation 2 . It also serves as the foundation for the subsequent articles in Chapter II, as payment service providers are required to use these agreed-upon terms in order to comply with the remaining provisions of the chapter.
In line with Article 27 of PAD, the following information on Articles 4, 5, and 6 concerning the level of compliance by payment service providers has been provided by Member States.
a)Article 4: fee information document and glossary
Article 4 establishes that payment service providers must provide consumers with a fee information document in good time before entering into a contract for a payment account. The document must be provided on paper or another durable medium and contain the standardised terms and corresponding fees for each service offered by the provider. The presentation of the fee information document is subject to precise rules laid down in an Implementing Regulation 3 . Additionally, payment service providers must make available a glossary of the standardised terms and definitions and ensure that the fee information document and glossary are readily accessible to consumers at any time, free of charge, and in various formats, including electronic form on their websites and premises, as well as on paper or another durable medium upon the consumers’ request.
As regards the timely provision of the fee information document to consumers, as stipulated by Article 4(1), the data indicates general compliance among payment service providers. This conclusion is drawn from conducted surveys, inspections or other supervisory checks and analyses (e.g. BE, CZ, DE, ES, FR, HR, HU, IE, IT, LU, LV, MT, PL, PT, RO, SI) 4 , and the very low incidence of complaints or lack of other indications of providers’ non-compliance (e.g. AT, BG, CY, DK, EE, EL, ES, FI, LT, NL, SE, SK). Overall, these findings suggest that providers are compliant. The information documents are also presented to consumers in various formats, including physically in branches and digitally on websites. In that respect, the Netherlands highlighted that while fee information documents are available on websites, they are not always easy to find for consumers. France noted the recent observation of a credit institution providing pricing information via a QR code, deeming it in compliance if it links to a durable medium that can be downloaded, printed or recorded, and if the information is available upon consumer request.
Regarding the requirement of payment service providers to make available a glossary of standardised terms, as outlined in Article 4(4), the data points to general compliance among payment service providers. This conclusion is drawn from surveys, inspections or other supervisory checks and analyses (e.g. BE, BG, CZ, DE, FR, HR, HU, IE, IT, LU, LV, MT, PL, PT, RO, SI), and the very low incidence of complaints or lack of other indications of providers’ non-compliance (e.g. AT, CY, DK, EL, ES, FI, LT, NL, SE, SK). Overall, these findings suggest that providers are compliant.
On the requirement to make available to consumers (and non-customers) at any time on the website and on the premises the fee information document and glossary, as required by Article 4(5), the data suggests general compliance by payment service providers. This conclusion is again drawn from surveys, inspections or other supervisory checks and analyses (e.g. BE, BG, CZ, DE, FR, HR, HU, IE, IT, LU, LV, MT, PL, PT, RO, SI), and the very low incidence of complaints or lack of other indications of providers’ non-compliance (e.g. AT, CY, DK, EL, ES, FI, LT, NL, SE, SK). Overall, these findings suggest that providers are compliant.
In a limited number of cases, anomalies were identified regarding the use of non-standardised terms and the provision of the fee information document and glossary. The respective providers were instructed to address the issues detected with appropriate remedial actions, but no sanctions were imposed as providers took measures to ensure compliance (e.g. ES, IT, PT). In France, one establishment that failed to provide the fee information document received an injunction to comply after repeated instances of non-compliance. However, nearly all Member States reported that no enforcement actions have been initiated regarding infringements of Article 4.
Most Member States indicated that consumer detriment decreased as a result of the requirements laid down in Article 4. However, several Member States pointed out that there is insufficient data to fully assess this issue with certainty.
b)Article 5: statement of fees
Article 5 of PAD governs the statement of fees. The statement must include a detailed breakdown of all fees incurred for services linked to a payment account. To ensure consistency and clarity, the European Commission has enacted an Implementing Regulation 5 that standardises the presentation format of the statement of fees and introduces a common symbol. This obligation aims to promote transparency and help consumers better understand the fees associated with their payment accounts.
In terms of the obligation to deliver at least annually and free of charge a statement of all incurred fees, as set out in Article 5, the data indicates general compliance among payment service providers. This conclusion is drawn from surveys, inspections or other supervisory checks and analyses (e.g. CZ, DE, FR, HR, HU, IE, IT, LU, LV, MT, PL, PT, SI), and the absence of complaints or lack of other indications of providers’ non-compliance (e.g. AT, BE, BG, CY, EL, ES, FI, LT, PL, RO, SE, SK). Overall, these findings suggest that providers are compliant.
In a limited number of cases, shortcomings have been identified, e.g. in Hungary and Portugal regarding to the compliance with information requirements of the statement. Some shortcomings have also been identified in Italy on the incorrect categorisation of products outside the scope of the PAD as well as the provision of the statement of fees less frequently than required. These shortcomings required the competent authorities to take action to ensure compliance (e.g. HU, IT). However, nearly all Member States reported that no enforcement actions have been initiated regarding infringements of Article 5.
Most Member States indicated that consumer detriment decreased as a result of the requirements laid down in Article 5. However, several Member States pointed out that there is insufficient data to fully assess this issue with certainty.
c)Article 6: information for consumers
Article 6 of PAD requires payment service providers to use in their contractual, commercial and marketing information to consumers, the standardised terms. This means that consistent and clear language must be used to help consumers understand the services and fees associated with their payment accounts. While payment service providers are allowed to use their brand names in the fee information document and statement of fees, these brand names can only be used as a secondary designation of the services.
On the obligation to incorporate standardised terms in the contractual, commercial and marketing information to consumers, as specified in Article 6(1), the data points to general compliance among payment service providers. This conclusion emerges from surveys, inspections or other supervisory checks (e.g. BE, CZ, DE, FR, HR, HU, IE, IT, LU, LV, MT, PL, PT, RO), and the absence of complaints or lack of other indications of providers’ non-compliance (e.g. AT, CY, BG, DK, EE, EL, ES, FI, LT, NL, SE, SI, SK). The data suggests that overall, providers are generally compliant.
Concerning how frequently payment service providers include their brand name in the fee information document and the statement of fees, the overall observation is that providers often do include the brand name. Several Member States indicated that they did not have sufficient data to assess this issue.
Regarding enforcement actions related to infringements of Article 6, almost all Member States reported that no such actions have been undertaken. Portugal noted that, between 2022 and 2023, three infringements were detected, which were followed up with warnings to comply. However, no further enforcement action has been taken. Based on a survey carried out in 2022, France highlighted that one payment service provider did not include all required information. However, following an injunction, the provider complied with the Article 6 obligation under PAD.
Most Member States indicated that consumer detriment decreased as a result of the requirements laid down in Article 6. However, several Member States pointed out that there is insufficient data to fully assess this issue with certainty, and a couple other Member States also highlighted a likely limited impact of Article 6.
3.COMPLIANCE BY MEMBER STATES WITH THE REQUIREMENTS TO ENSURE THE EXISTENCE OF COMPARISON WEBSITES PURSUANT TO ARTICLE 7
Article 7 requires Member States to ensure that consumers have access, free of charge, to at least one website comparing fees charged by payment providers for at least the services found in the national list of the most representative services linked to a payment account and subject to a fee. It also establishes that the comparison website may be operated either by a private operator or by a public authority, that it is operationally independent, discloses the owner of the website, sets out clear, objective criteria which the comparison is based on, uses plain and unambiguous language, is up to date, covers a significant part of the market and provides an effective procedure to report incorrect information on published fees.
Almost all Member States 6 have at least one operational comparison website, as required by Article 7. Most Member States have assigned the responsibility for creating and updating the website to a public authority. In Ireland, Poland and Spain several private websites exist in addition to a public website. In Denmark and Czechia, the available websites are run by private operators. In Finland, Netherlands and Sweden, both public and private actors are involved.
Croatia noted that its website also distinguishes between different types of accounts, such as basic accounts for consumers belonging to a vulnerable group. Some websites also provide information on other products or other comparison websites related to different products that exist in the respective Member States. Additional products include credit cards, insurances, mortgage loans, consumer credits and savings accounts. Except for some private websites in Czechia, none of the publicly available comparison websites in Member States appear to provide personalised advice to consumers.
Overall, comparison websites appear to be updated on a regular basis. Furthermore, several Member States emphasise that they require providers to notify website operators of any change, before or at the latest when the new conditions take effect (e.g. BG, DE, ES, HR, HU, LT, MT, LV, PL, PT, RO, SI, SK).
Only a few Member States reported that the reporting mechanism for incorrect information on published fees had been triggered (e.g. BE, BG, EL, FI, FR, LU, MT), typically requiring only minor corrections. Overall, this suggests that correct information is displayed on the comparison websites. On correcting errors, France highlighted its automatic verification process, which conducts quality checks on the information published on the website during the entry stage. Malta also emphasised that its competent authority reviews all changes before publication on the comparison website to prevent incorrect information from being published.
Several Member States have also launched specific public awareness campaigns through various communication channels, such as television, radio and social media (e.g. BE, DE, EE, HR, IE, PT). In addition, several other Member States disseminate relevant information on related public websites, press releases and reports (e.g. BG, ES, FI, LV, NL, PL, SE, SI). Moreover, Austria and Hungary pointed out that payment service providers must inform consumers about the availability of the comparison website.
Only a few Member States have carried out specific assessments of their websites, or plan to do so in the future. For instance, in 2020, an evaluation of the Dutch comparison website was carried out, including questionnaires targeted at both users and payment service providers. Based on the evaluation’s feedback, clear information on when the website is updated has been added. Luxembourg’s website was reviewed in 2023 and was made more consumer-friendly and handier. While Spain did not conduct a broad assessment, some evidence suggested that consumers experience difficulties in usage and that information does not always appear to be entirely up to date with current consumer preferences. Therefore, Spain is currently reviewing its website. Malta mentioned that it carries out periodic exercises to capture website visits and assess the effectiveness of the comparison website. Romania will run a project co-financed by the European Social Fund. The aim is to reduce administrative burden for individuals and businesses in consumer protection, which includes improving the comparison website so that it is more user-friendly.
4.NUMBER OF PAYMENT ACCOUNTS THAT HAVE BEEN SWITCHED AND THE PROPORTION OF SWITCHING APPLICATIONS THAT HAVE BEEN REFUSED
a)Payment accounts that have been switched
PAD establishes a quick procedure for consumers who wish to switch their account from one bank to another in the same Member State.
Table 1 shows the number of payment accounts that have been switched between 2016 and 2023. Not all information is available in all Member States and there are certain gaps in the data in the table. Given the late transposition in some Member States, a switching service may not yet have been available in 2016 or 2017, or the data has not been collected for these years. In addition, in some Member States, the data has not always been collected annually.
Furthermore, the data provided may not always be comparable given different methods of data collection. While in some Member States it is mandatory for credit institutions to report periodically (or on an ad hoc basis), data may only be collected on a voluntary basis or only from a sample of credit institutions in other Member States. In some cases, the data provided by Member States for 2016 may include switches that took place in the months before the entry into force of PAD (where e.g. a similar switching service had already existed in these Member States before the implementation of PAD).
Since the data collection exercise began, 17.6 million payment accounts have been switched using the switching service.
Table 1: Number of yearly switches
Given the data gaps and the lack of fully comparable data 7 , it is difficult to draw clear conclusions with respect to the uptake of the switching service or to identify any clear trend over the time horizon. It is however possible to note significant differences. While in some Member States a considerable number of switches have taken place, in other cases the figures appear very low. Of particular note is the high level of switching in France (1.2 million in 2023, down from 1.5 million in 2022), where the process has become well established.
According to Member State responses, the low number of switches in some other Member States can be attributed to a number of factors. These include (i) a lack of awareness about switching services; (ii) a lack of demand (due to minimal differences between payment accounts and use of multiple accounts with different providers); (iii) negative perceptions about the difficulty of the process; (iv) inertia; (v) difficulties to identify better value alternatives; or (vi) credit facilities or other tied services with a financial institution which may be difficult to transfer; and (vii) inconvenience connected to changing an IBAN number. Some Member States have taken action to further ease the account switching process 8 . Low uptake of switching services in some Member States may merit further assessment and discussion.
b)Number (and proportion) of rejected switching applications
Table 2 shows the number of switching applications that have been rejected between 2016 and 2023. The proportions have been calculated by dividing the number of rejected switching applications by the total number of applications 9 . The information is incomplete because data on rejected applications is not collected in some Member States. Furthermore, the data provided may not be fully comparable given the different methods of data collection.
Table 2: The number and proportion of switching applications that have been refused
In view of the data gaps as well as different methodologies, it is difficult to draw firm conclusions. However, it is possible to note very significant differences across Member States and to provide indications as to possible explanations, as provided in Member State responses to the questionnaire. The percentage of refusals reached 85% in Romania (2023), 49% in Spain 2020, 29% in Poland (2023), 27% in Ireland (2023), 27% in Hungary (2023), while in most other Member States the proportion of rejected applications is much lower 10 . Member States gave several reasons to explain why switching applications were refused. These include (i) errors related to the switching application form (missing, incorrect or inconsistent information, ineligible account types, illegible/missing signatures etc.); (ii) incomplete documentation; (iii) lack of cooperation between banks; (iv) negative account balances; (v) not meeting specific deadlines; or (vi) cancellation of the application by the user.
5.NUMBER OF CREDIT INSTITUTIONS OFFERING PAYMENT ACCOUNTS WITH BASIC FEATURES, THE NUMBER OF SUCH ACCOUNTS THAT HAVE BEEN OPENED AND THE PROPORTION OF REFUSED APPLICATIONS FOR PAYMENT ACCOUNTS WITH BASIC FEATURES
a)Credit institutions offering payment accounts with basic features (PABF)
In most Member States, all credit institutions that provide standard payment accounts have to offer payment accounts with basic features (BE 11 , BG, CZ, DK, DE, EE, IE, ES, FR, IT, LV, LT, HU, NL 12 , AT, PL, PT, RO, SI, FI, SE). In other Member States, only some credit institutions, i.e. those meeting specific criteria set by the individual Member States, are obliged to offer payment accounts with basic features. In these latter cases, the obliged credit institutions generally cover a large market share in terms of number of payment accounts.
Table 3: Member States where only certain credit institutions offer PABFs
|
Country |
Specific Member State criteria to offer PABF by credit institutions |
Total number of credit institutions obliged to offer a payment account with basic features (as compared to the total number of credit institutions providing payment accounts) and their market share |
|
Greece |
All credit institutions that provide payment services to consumers, except for credit institutions that provide payment account with only online facilities |
|
|
Croatia |
Credit institutions whose assets exceed EUR 1.99 billion must offer PABF. Other credit institutions may offer PABF |
7 banks out of 20 (assets exceeding EUR 1.99 billion), representing 94% of market share |
|
Cyprus |
All credit institutions operating in Cyprus are obliged to offer PABF, except for 3 very small locally incorporated banks |
14 credit institutions representing a market share around 94% |
|
Luxembourg |
Credit institutions with at least 25 agencies in Luxembourg and holding at least 2.5% of covered deposits must provide PABFs |
5 credit institutions which taken together represent most of the market |
|
Malta |
Credit institutions having 5 or more branches in Malta are obliged to offer PABF |
5 credit institutions offer PABF with a market share of 93.7% |
|
Slovakia |
Only credit institutions providing all banking services linked to a payment account with basic features as part of their business activity to consumers |
10 credit institutions |
b)Number of Payment Accounts with Basic Features (PABFs)
The information on the number of PABFs provided by Member States and set out in Table 4 is incomplete for certain years. In some Member States, credit institutions do not distinguish between a standard payment account and a PABF, so that no data on PABFs exists. Similarly, the information may not always be comparable due to different data collection methods. In some Member States, only some credit institutions offer PABFs as a specific product, whereas other credit institutions do not distinguish different types of accounts. In these countries, the figures therefore only cover the PABFs offered as a specific product.
Table 4: Number of PABFs opened each year
Given the data gaps and the lack of comparable data, it is difficult to draw firm conclusions 13 . Since it is not a requirement under Article 27, data is not available to indicate the total number of outstanding PABFs at each year end. The information provided in Table 4 shows that a considerable number of PABFs have been opened during the time period, reaching almost 2 million in 2023. The very high number of account openings in Romania is explained by the fact that the data show all types of account opening and is not limited to PABFs. Similarly in Greece, the high number of opening new accounts comes from the fact that customers use standard accounts as PABFs. The number of new accounts opened in France, Italy 14 and Slovakia is strikingly low.
c)Number (and proportion) of applications for payment accounts with basic features that have been refused
The data on the number of applications for PABFs that have been refused has been gathered by Member States (Table 5). The proportions have been calculated by taking the number of PABFs opened and the number of applications for PABFs that have been refused as the total number of applications 15 .
Table5: Number and proportion of applications for PABF that have been refused
The data is not available for all MS and may not be fully comparable. It is therefore not possible to draw firm conclusions. Nevertheless, the data indicates that the rates of rejection of PABF application are generally very low.
The situation across the Member States varies significantly regarding the reasons for refusals. Based on the questionnaire replies, the main reasons for refusals include: (i) compliance with money laundering and know your customer requirements; (ii) the customer already holds a payment account; (iii) the customer has had past negative antecedents with the bank; (iv) issues with documentation; or (v) the applicant is not resident in the EU.
6.CONCLUSION
The report confirms that the main PAD measures on transparency and comparability, the switching service and the right to a payment account with basic features, are generally in place. However, the differences in Member States’ data collection methods and the persistence of significant data gaps make it difficult to draw firm conclusions about the extent of the benefits that the introduction of PAD has given European consumers.
With those caveats in mind, we can nonetheless draw the following tentative conclusions:
·The information and transparency requirements under Articles 4, 5 and 6 are generally being complied with, suggesting an overall reduction of consumer detriment. However, the availability of more comprehensive and robust data would be needed to draw firm conclusions on the positive impact of these provisions on European consumers.
·Comparison websites are fully operational in almost all Member States. Several Member States have also conducted public awareness campaigns and provide information through various communication channels, which can play a vital role in raising consumer awareness. Only a few Member States have assessed or plan to assess their comparison websites. Regular assessments, incorporating feedback from both consumers and service providers would ensure more user-friendly interfaces as well as more relevant and easily accessible information for consumers.
·On payment account switching, the switching service was used by over 2.5 million customers in 2023, down from the previous high in 2022 of 2.86 million. Since 2016, there have been a total of 17.6 million account switches. In some Member States, the switching service is frequently used, in contrast to a number of other Member States where it is barely used at all. The reasons for such discrepancies are not fully clear and may require further investigation. However, anecdotal evidence provided by Member States suggests that inertia, lack of awareness and demand, perceived complexity (including around extrication from existing tied arrangements), customer loyalty, lack of obvious benefits to be gained from switching or inconvenience of changing IBAN may all play a role.
·There are also significant differences across Member States regarding the number of switching applications that are refused. Among the reasons for refusal given by Member States are (i) errors related to the switching application form (missing or incorrect information, inconsistent customer data, ineligible account types, incorrect forms, incorrect IBAN, illegible/missing signatures); (ii) too short deadlines; (iii) incomplete documentation; (iv) lack of cooperation between banks; (v) negative account balances; (vi) not meeting specific deadlines; or (vii) cancellation of the application by the user.
·On Payment Accounts with Basic Features (PABFs), gaps still remain in the data where some Member States have not provided the number of new account openings. The Commission does not hold data on the total number of PABFs at the end of each year and cannot therefore indicate how many people now hold such accounts. There are significant differences across Member States regarding the number of new account openings. This may be partly explained by differences in the way banks offer such features to their customers. For example, in some cases there is no differentiation between PABFs and standard accounts that incorporate the basic features of a PABF. While end-of-year data on the total number of payment accounts with basic features is not available. From the data provided by Member States it is possible to identify year-on-year increases – with the number of new account openings reaching almost 2 million in 2023.
·The rate of rejections of PABFs applications varies significantly across Member States. The reasons for this include concerns over money laundering, the fact that the customer already holds another payment account, past negative experiences with the bank, issues with documentation or because the person is not resident in the EU. In total, 24 545 refusals to open basic payment accounts were registered in 2023, representing 1.2% of the total number of basic payment accounts opened.
The Commission will follow up the findings of the report, including the low uptake of the switching service or high rejection rates for PABFs in some Member States, discuss them with Member States and explore whether further actions could be beneficial, including at Member State level. The Commission will also continue to work with Member States to ensure more robust and comparable data going forward.
The report also contains updated/complete data for 2021 which was also requested from those Member States that did not have the data for 2021 available yet at the time of the first report.
Commission Delegated Regulation (EU) 2018/32 of 28 September 2017 supplementing Directive 2014/92/EU of the European Parliament and of the Council with regard to regulatory technical standards for the Union standardised terminology for most representative services linked to a payment account, C/2017/6451, OJ L 6, 11.1.2018, p. 3.
Commission Implementing Regulation (EU) 2018/34 of 28 September 2017 laying down implementing technical standards with regard to the standardised presentation format of the fee information document and its common symbol according to Directive 2014/92/EU of the European Parliament and of the Council, C/2017/6456, OJ L 6, 11.1.2018, p. 37.
Country codes used in this report: AT (Austria), BE (Belgium), BG (Bulgaria), CY (Cyprus), CZ (Czechia), DE (Germany), DK (Denmark), EE (Estonia), EL (Greece), ES (Spain), FI (Finland), FR (France), HR (Croatia), HU (Hungary), IE (Ireland), IT (Italy), LT (Lithuania), LU (Luxembourg), LV (Latvia), MT (Malta), NL (Netherlands), PL (Poland), PT (Portugal), RO (Romania), SE (Sweden), SI (Slovenia), SK (Slovakia).
Commission Implementing Regulation (EU) 2018/33 of 28 September 2017 laying down implementing technical standards with regard to the standardised presentation format of the statement of fees and its common symbol according to Directive 2014/92/EU of the European Parliament and of the Council, C/2017/6453, OJ L 6, 11.1.2018, p. 26.
In Germany, a new comparison website provided by the public authority BaFin became available in January 2025. The previously available comparison website of a private provider was not compliant with the PAD according to a German court decision. The main reason was an insufficient market coverage. Also, the information on the website was not always up to date because the banks were not obligated to report their data to the provider. Therefore, banks are now obliged to continuously report the relevant data to BaFin. Although some private comparison websites have been available online for a few years, Italy is also still in the process of developing a comparison website that complies with the requirements of Article 7 of the PAD.
For example, certain data includes all types of accounts, not limited to payment accounts.
In Portugal, for example actions have been taken to address concerns about the low numbers of account switching. The Bank of Portugal has provided guidance in the form of a Circular letter indicating that payment service providers (i) must make available a switching account form, (ii) should make account switching available through digital channels when opening a payment account is also available through the said means, (iii) must inform consumers of the reasons of the switch account refusal, (iv) must make available forms with the new account information, to be presented by consumers to their creditors and/or debtors, when the consumer chooses to execute such task (instead of the payment service provider), (v) must make available in their websites, information about payment accounts switching and (vi) must provide their staff with the knowledge about the switching service.
(Number of refusals) / (Number of refusals + Number of switches).
In the case of Denmark, it is estimated by the Danish Banking Association, Finance Denmark, that no switching applications have been refused. Similarly in Lithuania, it is estimated that no switching applications have been refused.
14 credit institutions offer PABF end 2023. They account for 95% market share of consumer payment accounts.
Most banks offer PABFs as the most restricted version of their standard payment account: some banks offer PABFs as a specific product which is different from a standard payment account.
For example, the number for Germany shown in 2018 is a consolidated number for the years 2016-2018, or data in some Member States is not available for all years.
In Italy, the obligation to offer the ‘basic account’ is deemed to be fulfilled if the PSP provides the PABF as a specific product or if the PSP offers a ‘standard’ payment account which is free of charge at least for the services and number of transactions to be included in the PABF; in the latter case, the pre-contractual information on the account shall specify that it replaces the ‘basic account’.
.
Possible withdrawal of applications has not been considered (due to lack of data).