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Payment Services Law

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We advise our clients on all payment services law issues. In doing so, we can draw on our many years of experience in the payment sector, which makes us the ‘go-to’ law firm for this topic in Austria.

Our payment clients come from a wide range of sectors. In particular, we advise banks, payment institutions, e-money institutions, fintechs, telecommunications companies, retailers, intra-group payment factories, processors and other technical service providers, industrial companies, marketplaces and loyalty systems.

Our focus

  • Development and structuring of business models to avoid a licence requirement under the Payment Services Act and the E-Money Act

  • Licencing and registration procedures for payment and e-money institutions

  • Passporting proceedings

  • Utilisation of payment and e-money agents

  • Clarification of matters relevant to supervisory law with the FMA

  • Consultancy on how to fulfil the regulatory requirements for payment transactions

  • Creating process descriptions, work instructions and manuals (e.g. money laundering manuals, risk and thread analysis)

  • Card-based payment transactions (Issuing & Acquiring)

  • E-money, invoice and instalment purchase products

  • Marketplace systems and other platform-based payment solutions

  • Loyalty systems, vouchers and customer cards, as well as other prepaid products

  • Mobile payments and other alternative payment methods

  • Account information and payment initiation services

  • Drafting standard contracts and general terms and conditions

  • Cooperation and outsourcing in the area of payment transactions

  • Design of voucher cards, customer cards and loyalty systems

Meet the team

Dr. Bernd Fletzberger

Dr. Bernd Fletzberger

T +43 1 877 04 54
M  This email address is being protected from spambots. You need JavaScript enabled to view it.

Mag. Sanijel Ficulovic

Mag. Sanijel Ficulovic

T +43 1 877 04 54
M  This email address is being protected from spambots. You need JavaScript enabled to view it.

Christopher Falke

Christopher Falke, LL.M.

T +43 1 877 04 54
M This email address is being protected from spambots. You need JavaScript enabled to view it.

All our lawyers

  • Bernd Fletzberger ist einer der wenigen Anwälte, der im Bereich Payments aktiv ist.

    Juve Ranking 2024 (Bank- und Finanzrecht / Kapitalmarktrecht)

  • Bernd always makes sure to proactively take up issues and pushes them forward. He stands for excellence and state-of-the-art approach.

    Chambers Europe Guide 2024 (Banking & Finance: Regulatory)

  • Bernd Fletzberger is a highly respected lawyer in the banking and finance sector. A particular focus of his work includes e-money and payment services law. Here, he impresses with an extraordinary knowledge that is hard to find in the Austrian market.

    Legal 500 Guide 2023 (Banking & Finance)

    You have questions?
    We have answers.

    +43 (1) 877 04 54
    Contact us!

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    Relevant publications

    Handbook Payment Traffic 4.0

    Payment services covered by the ZaDiG 2018 and the e-money business in accordance with the E-GeldG 2010 (together with Christian Steiner), in Tuder (Hrsg), Handbuch Zahlungsverkehr 4.0 / FinTechs – Krypto-Assets – Sandbox & Co. (2024)

    Handbook Payment Traffic 4.0

    Freedom to provide services and freedom of establishment for payment institutions, in Tuder (Hrsg), Handbuch Zahlungsverkehr 4.0 / FinTechs – Krypto-Assets – Sandbox & Co. (2024)

    EBA Opinion on easy access to payment accounts

    EBA Opinion on aasy access to payment accounts, ZFR 2021/62, 155

    The amended scope of application of PSD2 and the ZaDiG 2018

    The amended scope of application of PSD2 and the ZaDiG 2018, ZFR 2018/162, 325