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This is a very good 'how to' post. There is more to payments, however, than card acceptance which is what this post is largely about.  What about issuing cards, or working with bank accounts, whether through open banking or even directly issuing payment accounts.  As the post states, it is all about anticipating and responding to pain points faced by online businesses.  With the increasing number of digital innovators, the payment industry is trying to address the pain points faced by new entrants who have an urgency to go to market as well as managing tight cash reserves.  There may be go-to solutions for card acceptance but it’s much harder to find solutions for any other payment process besides card acceptance.

Perhaps a more viable approach would have been for PSD2 to stipulate robust interoperability and data standards available to all TPPs, plus minimum banking standards of conduct for disputed transactions with a body (EBA?) as arbiter.  That would have made it so mch easier for PoS providers to invest. PSD3 maybe? 

Your point about timing is well made, Paul, but also note that PSD2 will only enable access to licensed third-party providers rather than the long tail of developers and innovators. 

In addition to enabling acces for innovators with deeper pockets, OPC is also looking to support the long tail of developers by inviting an initial ‘founder members’ group of financial institutions and payments processing vendors to the OPC.