The road from a European directive to a payment that really works at the till.
The European PSD2 directive gave clients the right to pay directly from their account. For that right to hold at the till, somebody had to walk the whole road - from the EBA opinion through the Czech National Bank to remedy dates at the banks. Here it is.
The European directive opens bank accounts to licensed third parties. On paper this creates the right to pay directly from your account - anywhere.
The European Banking Authority names the technical obstacles banks put into PSD2 payments - and which, under the regulation, have no place there.
After three years of proceedings, Mo.one (then ZNPay a.s.) obtains a licence from the Czech National Bank for account information and payment initiation.
Licence detailWe built connections to eight Czech banks. Technically it worked - but the payment experience was spoiled by extra steps a client never meets with a card.
Dozens of pages of analysis: exactly what banks insert into the payment flow, why it is an obstacle under the EBA and what the directive says. Submitted to the Czech National Bank.
The Czech National Bank confirms the obstacles and clarifies what banks may not do during a payment. From this moment the Czech market has clear rules.
The opinion on cnb.czThese are the extra steps that both the EBA and the ČNB labelled prohibited obstacles - and which are gradually disappearing from payments.
Source: EBA Opinion on obstacles (2020, Article 32 RTS) · ČNB opinion RS2025-28.
The whole market has now given a remedy date except UniCredit Bank and mBank. With those two we are continuing through the courts.
Remedy completed
App2App works for connecting an account and for payment, on Android and on iOS.
A date for remedying the user experience confirmed.
Early 2027
The bank is adjusting the payment flow in coordination with the ČNB.
A date for remedying the user experience confirmed.
Q4 2026
A date for remedying the user experience confirmed.
Partial remedy
Connecting an account done, payment according to the schedule agreed with the ČNB.
22 November 2026
A date for remedying the user experience confirmed.
An action for unfair competition and lost profit · plus a submission to the competition authority. We have a licence, a business plan and the right to carry it out.
A specific schedule of fixes · by 9 to 11/2026.
No date set · we are continuing through the courts.
Two of the four sued backed down and gave specific dates. The action worked · we pushed the regulation through.
This is not an experiment. Whole countries have already done it.
The share of cards in payments. Where local direct payment arrived, it fell within a few years.
Sources · Banco Central do Brasil · RBI 2024 · ČNB and SBK · ECB SPACE 2024
We sent the ČNB dozens of pages of analysis: what is wrong in bank interfaces and what a direct payment should look like. Opinion RS2025-28 reached the same conclusion - since 27 November 2025 it applies to all banks, and the largest of them are to fix their interfaces by the end of 2026.
Opinion RS2025-28 on the ČNB websiteThis is exactly how Mo.one has been built from day one.
Choosing a bank at the merchant or a third party
Authentication of the user and authorisation of the payment in the mobile app
Automatic redirection to the website or app of the merchant or TPP
Direct payments work today - and every quarter they get simpler for your customers. Work out what that does to your costs.