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In this Christmas episode of the Payments Trilogue, hosts Michael, Ralf, and Gijs discuss their Santa wish lists for the payments industry, focusing on regulatory improvements. They explore the implications of upcoming regulations like Instant Payments incl. VOP, PSD3/PSR, FIDA, eIDAS 2.0 and the need for better APIs, as well as the strategic importance of initiatives like SPAA and the digital euro. The conversation also touches on the challenges of cash acceptance and the need for innovative thinking to leapfrog existing solutions in the payments landscape.
Chapters
- 0:00 Introduction to the Christmas Episode
- 1:20 Ralf's wishlist for Instant Payments
- 5:30 Gijs' wishlist
- 7:27 Michael's first wish
- 8:22 Ralf's wishes for PSR
- 11:48 PSR wishes from Gijs
- 15:00 More wishes from Michael
- 15:56 SPAA
- 20:19 Industrial policy
- 25:57 Digital Euro and EUID Wallet synergies
- 33:31 FIDA and Customer Data Access
- 38:15 Cash acceptance and regulatory concerns
- 39:35 Leapfrogging in payments innovation
Transcript
Michael Salmony 0:00
Welcome to the Payments Trilogue, where three seasoned professionals discuss payments and more, for Europe and beyond.
Hello, my name is Michael Salmony and as you can see and hear we are doing the Christmas episode of the Trilogue this time. I am joined as always by Ralf, you can see with the Father Christmas hat on, and Gijs who looks a bit more like a lumberjack, but we'll take what we can get. So what we thought we would do for the Christmas episode is do some wish lists. Ralf would say a few things what he would wish from
banks and the regulator from the fintech point of view and Gijs similarly.
But before we go in there, I just want to thank everybody who's watching this, this, Trilogue. seems it's really catching on, although we've only done about six episodes. I'm getting thousands of views when I repost, for example, the last CBDC episode and 800 downloads of the paper I wrote about it. So thanks for all the lovely comments I'm getting personally, and that we're all seeing in the statistics. Okay. So before we,
Now let's get into the dialogue and maybe Ralf, you can kick us off with a few things on your wishlist. Okay. Yeah. Well, I have actually a long, long list. It almost feels like back into childhood because as you know, as I grow older, my Santa list got shorter and shorter. And actually these days, I'm not sure I have any. So
Different for my kids, they have long lists. And so today here with talking about my regulatory or bank wish list, I'm feeling back into that more childish, hopeful, wishful, optimistic way of approaching this. I would like to start with the most imminent regulation coming in, which is instant payments.
So here, I guess the wish is not so much more on the regulators because their job is or the cool legislators because that is done, the legislation is coming in. So here, my main wish is really to the banks and it's a very important one. So you may know that the instant payments are supposed to be
or cannot be more expensive than non-instant payments. So that's a part of the regulation. But we have just seen some banks in Spain or at least one bank in Spain increasing non-instant fees. And I guess it's exactly what we were afraid of that maybe some banks will try to avoid zero fees for instant payments by now starting to charge for the non-instant.
And that, I think, would be a very, very unfortunate development. and of course, actually twofold because, you know, from a PISP perspective, when you do payments via PIS, it basically lives from the fact that non-instant SCT payments are typically free of charge to the consumer, so they don't have to pay anything for making the payment itself. And if that changes, then we have a problem for non-instant payments.
And of course we would have then the same problem for instant payments going forward that people wouldn't use it. They would not use a payment method where you got to pay for the payment itself because you will have free alternatives, cards, et cetera. So that for me is one of the biggest wishes for next year. And, yeah, well, we have,
Well, another wish or hope that with the first deadline coming in January where we have the receiving of instant payments becoming mandatory and in October then the sending from our perspective, we really need the sending. So therefore, hopefully some banks will do both in one go and we'll get the sending right away in January and don't have to wait.
another nine months to October for having the sending enabled as well. And the last one is on this verification of payee, where I think we do have some common interests with many banks that most TPPs, I think, do not really want to get pulled into that whole thing and overhead and doing all these verification of payee. and thankfully, the Berlin Group has implemented their flag in their standards, VOP standards, where the TPP could say,
bank, please do the VOP or don't do it because it's unnecessary because we can use this exemption where the PISP has already, you know, KYC the merchant and there is no need for a transactional VOP anyway. So for me, instant payments, that's the, that's my three wishes on that one. Okay, wonderful. So Gijs do you want to react to that and maybe add some of your own? no, I'm not going to react. have my own wishes. So
Ralf is entitled to his wishes and is allowed to keep on dreaming of course. That's a good reaction. So but staying at the topic of instant pain so that's I think well indeed the verification of payee was also on my list. Hopefully we get a smooth implementation of the varying VOP initiatives that they all will indeed become interoperable, that they all will use the VOP scheme, the overlay.
scheme of the European Payments Council. have high hopes on that one. And hopefully it will help because that's the whole idea behind it. It will help fight fraud or at least mistakes in erroneous payments. So it's going to be a tough nut to crack across Europe. believe we have lot of experience already since 2017 in Netherlands. It is not an easy thing to do, but there are lessons learned and I really wish that it's going to be implemented well.
apart from these exemptions that Ralf is mentioning that's small, but that in general it delivers on the promise it holds to make payments more secure and more safe. One more technical thing in Instant Payments is that the timeline of 10 seconds, according to the EPC rulebook, may still be a little thing we have to look better at to make the Instant Payments really, really compatible in terms of transactions speed.
for a good point of sale, especially in the physical retail point of sale, alternative means to cards. would be QR code, barcode or NFC based, whatever based initiation. There might still be some work to be done to really get the transaction speed we need to compete with the card-based solutions that are out there today. So that would be my two wishes for Instant Payments, the most important ones.
Okay, excellent. Thanks very much. We already did some episodes both on incident and fraud. So I won't comment any more on that. I think we already said something about that. I do also have some wish lists for you two, both of you and also for the regulator. Just to bring one for you two, my wish list is that you would work together more. I think the enemy is not the enemy of the fintech is not the bank. The enemy of the bank is not the fintech. You can both win if you work together.
because the enemy is actually elsewhere, if one can say an enemy, but we need to ensure sovereignty and we need to make sure that we serve the clients, both consumers and corporates better. And that's only going to work if banks work together and banks and fintechs work together. So that would be my first wish and I will come up with other wishes towards the regulator later in the episode. But Ralf, you said you had a longer list, so what are your next things?
Yeah, yeah. So from now looking at the still outstanding new regulations, of course, top of my mind, our mind on a TPP side, FinTech side is PSR or PSD3, but PSR in particular. And there
Yeah, we had an episode, so I will not spend too much time on it where I explained it in more detail. But I think for me, there number one is really that we should get away from this, I don't know, strange idea of providing a dedicated interface. So yes, we want APIs, we want machine to machine automated interfaces, but it should certainly not be dedicated to one party to TPPs. The more parties are using an interface, the better.
And we have already quite some examples, again, with a Berlin Group where many of the APIs are to be used both by TPPs and by corporates. So all these extended services are all to be used or mainly actually signed for corporate access, corporate direct access. And these are the APIs we want to use. So it's not of an advantage to the bank if they have to maintain the dedicated, special, separate interface for banks, sorry, for TPPs.
And it's better for the TPPs as well. If we don't have an exclusive one to us, because this exclusivity doesn't come with advantages, really only disadvantages. leading to the second point that we, of course, we need better contingency for all those APIs that do not work well. And there are still, unfortunately, the majority, as I explained in our last episode on that. One other thing.
Also very important is that, and I don't know how to achieve it, the, want to please Santa help me in making people understand that the PIS service is usually typically in most cases, not a service to the payer. It is a service to the payee, to the merchant. We're paid by the merchant for helping them.
It's one payment method like cards, like whatever, all the other ideal, etc. So it is a payment method that is the merchant is paying for. and it's therefore typically most PISPs are so-called merchant sided PISPs or payee PISPs and have no relationship, no contract or no nothing with the with the payer. And therefore
Yeah, so that hopefully the council will understand that their ideas, which are opposite, are actually not the reality of the market. Anyway, and the other thing I also, I think it is important to mention it again, that I think in terms of governance, because we identified that many, many of the problems that we've had were down to governance, focusing maybe on security and basically not
little very little on competition and basically nothing on innovation. So having competition authorities involved would be also on my wishlist and I have 20 more just on PSR. I will not mention them again. You were super clear on what you said there. That's great. Gijs, what do you think? Yeah, I agree with Ralf. It wouldn't it be nice if we could
unpack one little present and it would be a nice and shiny uniform API inside of it that everybody can use. But we're a long way from that yet. we're making progress. It's a long way, but eventually we will get there. I fully agree with you, Ralf, that this needs to be taken care of. But it will take time, unfortunately. One other totally different thing on my PSR.
which is two things. One is the ongoing discussions on what we call the subjective definition of authorization, meaning in the context of authorized push payment fraud, where a customer is defrauded by somebody telling, I'm from the bank, your money is at risk, please transfer your money to account XYZ. And that's of course the criminal's account. And why it's kind of customer actually authorizes the payment, him or herself.
So far that was legally binding, you did it yourself, there are leniency frameworks for that, now in the discussions we are going a little bit over the part of parliaments a little bit overdoing it. by saying well, authorization, if I'm defrauded and I did authorize the payment, but in hindsight I didn't want to make the payment, then it should become unauthorized and the bank should refund the customer. That
is a very fundamental flaw thinking because that would and that's also in the interest of the PISPs would basically go to the payment security in general because anyone could contend, I made the payment, yes I did it, I don't deny that, I authorised it, initially but in hindsight I didn't want to do it so I want my money back, that is a very dangerous...
development we believe in PSR going on. We know in the council working groups, but this is absolutely fundamental that should not happen. Of course, consumer protection is one thing, but payment security and payment certainty is another. And this is absolutely the wrong balance here. Very dangerous. A little bit attached to that. I think we need more room for data exchange to fight criminals. This is the tension between GDPR
and what we need in terms of data to effectively fight crime. GDPR is not out there to protect criminals, but unfortunately it makes it extremely difficult to effectively exchange data between financial institutions, be it banks and/or PISPs in the ecosystem to lay bare patterns that individual institutions cannot see, you cannot warn each other, hey guys, this is a criminal.
Of course we need to better address that. We are too naive and not saying it's not a fundamental right on privacy. But here a better balance has to be struck because the only ones profiting now are the criminals and we can't let that happen.
Very good. You both made very punchy points. That's great. For my first points versus the regulator, I'm going to say something not very original, but I will come up with two more things which I think may be a bit new. The not original one is more principle-based regulations and not so much in the details. We've seen, for example, in the SCA and various other things that they are just far too detailed.
where the market doesn't have a chance to move. And the second one is evidence-based regulation, only when there is a real market failure or when there's a real evidence need and where that instrument that is being proposed by the regulation that actually remedies the problem. And when we talk about CBDCs and various other things, I think we can see some issues there. So principle-based regulation and evidence-based regulation would be my wish list. But Ralf, you haven't finished.
Yeah, yeah. And I have some channel points, which I want to leave myself to the end. So I'll come back on that one, actually. yeah, we're sticking with payments for the moment. So what springs to mind next is SPAA, our SEPA payment account access scheme that we have launched last year. We're, well, trying to pilot. And yeah, so dear Santa, please make some banks join it.
And I think we have bent over backwards from our at least from our perspective that we are basically reduced all the or any obstacle any no minimal product any that there is is actually any bank could join today without having
or at least the pilot without having to develop anything because I'm sure they have already implemented, they have already functionality which goes beyond the basic regulation which they could start selling there without much new investment. Yeah, I mean, there is of course also the, know, the Berlin Group version two coming in that most banks I guess will also implement and that will give another push in the same direction where there will be functionality then available.
that might not be mandated but could be monetized here in SPAA. So please give it a try. I'm fully with you, Ralf. Same present, but a different formulation of that. What my wish would be is is awareness at C- level at the asset holders, i.e. the banks of the strategic importance of SPAA with a
a framework multi-stakeholder developed framework with a compensation model inside of it, which sets the example for the open finance frameworks beyond payments. That's why we developed it. And unfortunately, we have to keep repeating why we did it and what it holds in terms of promise to make people aware. another wish would be, because I do believe you mentioned the open finance framework of the Berlin Group,
One of the things that is hindering a quick adoption is the PSR process because banks will only jump to the open finance framework once the PSR is there, once there's legal clarity what that means from a compliance perspective. So they have still, unfortunately, a wait and see attitude because PSR is not yet there. And they will only probably take time to sensor also to SPAA because then you kill two birds with one stone.
If you have to do PSR anyway, can just as well do SPAA because that's a trivial extra effort. So unfortunately, the legislative process of PSR is not helping SPAA. There is a connection there because of the standardization of the burning Group specs, which is of course on the backlogs and banks will be have to be compatible and compliant with the PSR world to get there and have to transfer to the open finance framework of the PSD. But they can still...
wait, they will still wait until there is legal certainty, i.e. PSR enacted. So I will also hope, and the signs are not very positive as we read developments in Brussels with the coming presidencies, I have no high hopes there. So I'm not sure how we have to cope with that, Ralf, with regard to SPAA. But the, well, I do believe there is a strong dependency
The quicker PSR is enacted, the more banks will join SPAA because they will have to make the little investment from PSD2 to PSR compliance. We've made a study, we've shared it with the SPAA multi-stakeholder group, know that Ralf. If you have to jump from A to B, you could just as well do C, IE, become a SPAA member. And C level must
also understand the strategic importance. seems a little thing, a trivial thing. doesn't require hundreds of millions of investments. As you just said, Ralf, and that is one of the collateral damage. It is so small. It is so obvious that people are overlooking it.
Yeah, very good. I mean, obviously completely agree with what you're both saying. SPAA is at last a framework where everybody has fun, right? Everybody gets complicated and it's on agreed levels which are tolerable or attractive for both sides. It's been arranged by both sides. It'd be really sad if that weren't now being adopted from all sides. But let me on that note make my one first
wish to the regulator, which is maybe a bit controversial, and that's on industrial policy. We see industrial policy in other areas like agriculture, where the state has some steer and make sure that not everybody breeds pigs, but we have some pigs and wheat and barley and grain and chickens. So there's some steer from the state to make sure that subsidies are put in the right place and that we cover the market in an appropriate way.
Now in payments, I don't think we have that. We have a sort of high level retail payment strategy, which is full of lovely good stuff about transparency and fairness and equality and everything. And we have some super detailed regulations on at the bottom level, but there's not much steer. And that means that, for example, the industry is now creating EPI and EuroPA and SPAA and EMPSA and 15 other things.
And we're all breeding chickens. We're all trying to solve the same problem instead of getting some steer and maybe also some subsidies from the state to make this sovereignty happen. It's a controversial topic, I know, but I would just want to put it out there that maybe we need to think about an industrial policy for payments. But back to you two, Ralf. Yeah, well, could I react to that? Because it is a bit controversial, I would say.
I know, and we had these discussions now in various for the last few weeks and months and various conferences also, for example, at the Commission's expert group on payments about do we have too much of it now here in Europe and trying to make European payments great again in too many ways and
rather than focusing on one way. I just don't think it is possible. So I think we'll cover it or have covered it already, the various types of account to account payments and et cetera. I think the main thing here is that from a regulatory perspective, I wouldn't see that they should steer it in this direction or that direction. If anything, there was already too much steering in the direction of EPI in particular from my.
point of view, because of course, we are in we will be in competition, you can't combine this, like the, the EPI approach and the PISP approach, it's a different way of doing it. And I would argue probably similar with EMPSA and others. So there is, and I think there must be competition, the role of the regulator is to make sure there is a level playing field. That really, really is the important thing. And honestly, I don't think we are there yet. So but
So I want a more level playing field and then those with a better offer will win or will get a higher share. And I wouldn't mind if in the future we'll have 20-20-20 % market share for different European players rather than all in one pot. Yeah, I think a little bit in the middle because when you were saying that the level playing field, graveyard is also a level.
field. While I'm intellectually, of course, fully concurring, but I have come to the conclusion that unless we have some more strict and new with our own conference, Ralf, at the 7th of November, also the commission was present, I would like to have a little bit more steer. Also, I find it funny how can it be that in the eIDAS
Another Directory General DG-Connect is co-funding large-scale pilots, whereas in payments we don't have that. How can that be? Guys, give us a couple of billion to ticker the Tinker with and come up with solutions. And I can well see, Ralf, that you would have two large-scale pilots in payments, one for the open banking part, the PISP, the other one, the more EPI-like stuff. Anything is possible in a sensible way, but I...
I have come to the conclusion without more steering, think there are more on the side of Michael. We're not going to make it if we have geopolitical ambitions. We can also stop having those ambitions. All well and fine. Let's live on the level playing field and let others play on that field too. Fine with me. It all depends on what's the problem we're trying to solve here. Okay, I've stuck my hand in a bit of a wasps nest here. Sorry, I don't want to disrupt the... I do as a role of the state as a convener.
to bring people together and say, look, this is ridiculous. We're doing seven parallel things. Can we do that? And subsidies, obviously not the banks, they already have enough money, but they could subsidize actions or schemes or they could do something. This brings me very nicely actually to the digital euro.
already discussed and shown that I think we more or less agreed that we would prefer it not to compete so much with existing private solutions. yeah, staying out of this game here and sticking to where public money, ECB money is and has been sitting in the past, not in the form of notes and coins, but in the form of digital tokens. So yes, digitize it by all means.
but keep it in that spirit of having like a token in a wallet, which is handed over from one person to the other or from me to the merchant in a shop. Peer to peer settlement, not account based, not third party settlement, not going behind the rails on the backside and all of that. So I think we've discussed it before, but therefore let me just...
bring another topic up quickly in here, which we will discuss in the future, the European identity wallet. yeah, so my wish for that is that, well, we can use the synergy here with a digital euro so that the digital euro wallet and the identity wallet could be combined or could be both or the identity wallet could contain digital euros.
And in particular, so that this would be, I think it's an absolutely unique coincidence, but it's a unique opportunity to have the introduction of the identity wallet here coincide with actually having the ability of having digital euro tokens in that wallet and use it there. that's one. And otherwise on the identity wallet, of course, we hope that this will provide a real alternative to
to SCA flows where they are not so good. And there are many of them which are not so good. And here hopefully we'll have an alternative with a biometrics, easy, identify, authenticate a payment thing. And so we hope that that will work out. Excellent. Gijs? Yeah, well, on the digital euro first. My real wish would be, and again, it ties a little bit into what we just said about steering.
It should be a true public-private partnership. I also talked to EuroCommerce about that. We have to do it together and it still is not a real public-private partnership, the digital euro project. It's seen as that and felt as that by the ECB. They are communicating and reaching out a lot. But somehow we are not really in it together as a guys, this is how we're gonna do it. This is what the compensation model looks like. This is how it fits concurring also with Ralf.
how it fits in the ecosystem, what is the problem we're solving with this from a payments perspective that is monetary anchor stuff that's beyond me. But in the payments ecosystem, where should it fit there? I often concur with Ralf, creating a lot of confusion and it's very frustrating. Much of the intellectual oxygen is sucked out of the payments ecosystem and goes into probably useless discussions and fighting each other in the digital euro context. That's very frustrating because we could
turn it for the good of Europe but then something has to change in the steering of it and the real partnership with the need that there's something in it for everybody including a compensation model for those poor banks. Of course not a subsidy but a cost recovery model that is. On the eIDAS
everything, of course, has an up and a down side. It should be part of the bigger plan. What we see happening now with the large scale pilots, the consortia being formed and the old consortia, the old four and the new two that are being formed. We also see that from a geopolitical perspective, there are some funny participants in those LSP's large scale pilots. We may not fit in the geopolitical intentions we have here. I'm not naming names here, but...
We do need to be very very wary that the eIDAS and the EUID wallet is not turning out to be some form of Trojan horse. I'll stop there. We have to really think strategically and that's the problem with all these developments. jump on the bandwagon because we're all excited at what could technically be done without first thinking through where this will get us in the end.
and who we do want to be on that train and who we may not want to be there or jump on later. So we fail to have strategic thinking at the highest levels and that comes back to your industry policy, industrial policy thing a little bit I think. For the banks I think, and that's what we're doing right now and I think our guest is also involved in that, what does that mean? What it really means, the problem here is that
the eIDAS and the EUIDW will come from another Director General than DG FISMA, which we are usually talking to with regard to payments. It's more a telco-ish thing. DG Connect, okay, strong user authentication is the same as strong customer authentication, which means that anyway, you'd have to do that. You have to accept the EUID wallet if the customer wants that. But then if we ask a question, what exactly does it mean? If one Director General says, well, we don't know because we are not...
We don't have the mandate to talk about payments. The directorate that has the mandate to talk about payments says, well, we can't say anything either because it's not our regulation. So we have to figure our way out to get an industry position on what we believe is the compliance part of it. And that's what we're trying to get our heads around because banks need to be able, because the law is the law, to accept the EUID wallet.
If member states of course will be in time producing it, that's another matter, but banks need to be compliant by end-27, which means you have to invest into 26 or the budget to become compliant. And we're only starting to realise what it means. So for Ralf, it's easy. it would be ideal, would be great if we could use it. But on the acceptance level, at the bank's level, we haven't figured out yet what it means to become compliant, what the cost of that would be.
Maybe it's not going to be used at all because it's up to the customer to say, no, I want to use the SCA of my bank or I want to use the EUID wallet. We really need to figure that one out quickly because banks will have to start investing heavily for something that may not be used at all or only in small volume. So this is going to be a compliance cost for the banks again. And it's on your wishlist, but you're not going to pay for it.
Well, I think it will be used. if the Nordics are any indications or the bank ID and wherever we have an identity solution in the market today, like It's Me in Belgium, etc. So it's really heavily used and I think very well adopted. well, I have one more bigger subject here. I don't know if I should go in maybe right away, which is of course FIDA, open finance and what we're doing there. we
Well, again, we're having a separate episode on it. But in summary, for me, the main point is that FIDA should all be about enabling customers to get access to their data, full stop. So it should all be about allowing or basically forcing
data holders to give not just like GDPR based within 30 days or so access to the customer data, but in this day and age come to the 21st century and allow real well 24 x7 access, basically a user interface. in the finance world, mean, all the banks have it anyway, many, many, many other
like for investments or securities, most have it as well. Some insurances have it already, not all of them, but I think the vast majority has it already. So it's not that much asked here for those who are not there yet to provide this interface. And then if that is there, I think data holders would be well-advised to make this interface.
or design it in a way that it can also be accessed automatically, i.e. an API-based interface, like they all have for their mobile applications. So that already is good enough. an API-based interface, 24x7 accessible interface, that's it. And while we're on it there, and then leave the whole thing about schemes and how to...
stakeholders, what they should do, how they should do it, how much they could charge for it, etc. Leave that please to the market like we've done with SPAA. We were not forced. We still can come together without regulation, without any over regulation. They're getting into basically telling us how to do things. That really is not good.
Yeah, but there is the and also how that also answers the question on the scope of it, because of course it is the customer's data. So it's the customer who should then decide on which of their data they want to access or not. And whether it contains my pension or my health insurance or my life insurance or my whatever other insurance or my savings account, investment account, et cetera, it's my data.
How come, how dare dear regulator, how do you dare telling me that, yes, I can have access to my car insurance, but not to my health insurance data. Why? It's me and my data. So I do not want such a regulation that limits the scope of customer data access in the financial world. So that really, I think is one of the important points. And then here the council is coming up with suggestions in the latest.
in the latest draft, think it's actually almost agreed now, where they are suggesting that as the data user, as it's called, like the TPP or the FISP in FIDA, would not be allowed to then, well, use that data with any other company. So you cannot forward any of that data. So if, for example, I would, the customer wants, if I, as a customer, I want to have
my give some my financial data to my accountant, like a corporate customer. I'm going to interrupt you. No, is a Christmas wishlist to the council. think this is really important. So sticking to that, to that example. So if I want to give my data to my accountant, now, you cannot use a TPP who can then
forward that to the accountant. The accountant has to become a TPP or a FISP themselves. This is stupid, really. And that has to go away. by the way, I think it's not in line with PSR, it's not in line with GDPR. I really don't understand some of these stipulations coming up there. So please, Santa, let many of those bad ideas around FIDA go away. I think I'm going to call holds to the wishlist.
our time is gradually exceeding and I think the listeners will see that. Sorry, I have one more because Ralf took so much time about his open data exchange. I'm entitled to do one more wish. I'm sorry. And that is a totally different one that is cash. The good old cold hard cash the bank notes and in the slipstream of the digital euro regulation, you have the legal tender.
a regulation, mandatory acceptance of cash, basically without any exception. This is a dangerous thing, we believe cash of course remains important, but if this regulation doesn't allow, will not allow for let's say proportionality and that will differ from jurisdictions to make exemptions for the mandatory acceptance of cash.
let's say for public transport or parking or vending, all the non-attended stuff, it's still we're trying to get our heads around. I mean, it would have crazy consequences if there would be no exceptions for any vending situation. You have to accept cash everywhere. So we would plead that would be my proportionality in the mandatory acceptance of cash.
Okay, Gijs, I know there's no attempt to ever discipline you, so thank you for adding that up as well. So you two have given super long wish lists. As I say, I was much more modest. I have one wish list for both of you. I've voiced one wish list to the regulator. And as a final thing, since we're coming to the end of our time, would be just another, maybe slightly, I don't know, new, but controversial wish for the regulator. And that is leapfrog.
I think we're looking so much at how to catch up with the Americans and with the Chinese and then trying to do another Visa MasterCard, another PayPal, another this, another that. And that's proved historically very, very difficult. If you look at the success of various initiatives, Paydirect, Giropay in Germany, if you look at the attempts to try and oust cloud by European cloud.
There's plenty of evidence in the market that it is incredibly difficult that once others have got entrenched, to get rid of them. So I would just put out the idea there, how about thinking of leapfrog? How about thinking of something new, which the Europeans are really good at, and we build something that the Americans have to catch up on. I have some ideas on that. We don't have time to explore that now, but I just want to put the idea out that maybe not always catch up and sovereignty and try and...
try and reproduce what others have already done, but to try and think of something new. And as I say, there are some ideas there and maybe we'll explore that in another episode. Yeah, leapfrogging to sovereignty. That's a good theme for one of our next episodes. How about that? I think we've given quite a taste to the listeners on what we're going to be talking about on FIDA and on identity and maybe on leapfrog. So I hope you will join us. So now thank you very much to our Father Christmases and our Lumberjacks.
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