This high implementation cost could be put down to the fact that the PSD will impact multiple banking channels in subtly different ways, making the overall process incredibly complex. Because of this, there is a concern that some channels will be neglected - past implementations of regulatory initiatives have shown that the ATM is often left until the last minute as the forgotten channel. EMV roll-out is a case in point where the ATM was an after-thought. There was a lack of consideration for the impact on the channel, leading to confusion and difficulties in migration.

It is vital that banks find solutions to comply with the PSD now by evaluating how it will impact all the relevant channels (including the ATM), but this isn't being made easy by the scope to interprate the Directive in different ways. This lack of clarity over exactly how various points need to be implemented will doubtless give rise to significant consulting opportunities for vendors.

Hopefully banks may use the PSD changes that affect the ATM channel as an opportunity to innovate at the channel (and bring their most frequently used customer touchpoint out of the dark ages), rather than just do the bare minimum to keep on the right side of the regulations. Somehow, in these hard times, I suspect they won't...