In January 2012, the European Commission (the Commission) published its Green Paper 'Towards an integrated European market for card, internet and mobile payments' for a three month consultation.

In April 2012, the European Payments Council (EPC) published its response (see below) to this Green Paper. The EPC response outlines key policy considerations which, in the view of the EPC, should be observed when determining the need for European Union (EU) action impacting the European market for card, internet and mobile payments. The EPC does not support a number of related assumptions and suggestions put forth in the Green Paper. Consequently, the EPC believes that many of those suggestions will not help achieve the stated objectives and may even undermine their realisation. A thorough factual analysis of the EU payment landscape is however a prerequisite for any conclusion that further regulatory action may be required. Key considerations of the EPC with regard to the Green Paper are set out in the introductory section of its response.