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Implementation of the PSD II in Greece

The PSD II has just been transposed into Greek law via Law 4537/2018, effective from 15 May 2018. The transitional provisions of Article 109 of the PSD II for existing payment institutions, payment initiation and account information service providers, have also been introduced without changes.

As a general comment, the implementation of the PSD II was performed without significant deviations. From the optional provisions of the PSD II, some have been fully implemented – Articles 24, 29 par. 4, 61 par. 2, 63 par. 4 of the PSD II) – others have been implemented with some changes, namely articles 57 par. 3 and 58 par. 3 of the PSD II, and there are also some optional provisions which were not adopted at all – such as articles 32, 34, 86 and 101 par. 2 of the Directive.

The Bank of Greece has been appointed competent supervisory authority for authorization and for ensuring continued compliance with the Title II provisions of the PSD II and the Law. On the other hand, the General Secretariat of Commerce and Consumer Protection of the Ministry of National Economy is designated in accordance with Article 100 of the PSD II.

The Council of State is the competent court under Article 25 of the PSD II, in case a decision or failure to act of the Bank of Greece is contested via an annulment petition.

Greek credit institutions and the market in general have been rather slow in preparing for compliance with the provisions of the PSD II – but will definitely have to become more energetic on this front with the adoption of Law 4537.

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