In the special Het Financiële Dagblad edition publication of December 8th, 2025, ACG International’s Managing Partner, Edith Nordmann contributed on a topic that quietly affects many platforms.

A consumer pays, a service provider delivers – yet the funds may still be held by the Pyament Service Provider (PSP).

Not because anyone acted wrongly, but because the platform’s contracts don’t reflect the PSP’s compliance duties (and consequences for the parties involved).

And when rules on risk, fraud or chargebacks apply, the entire chain can get stuck: service providers wait for their payments, consumers face delays, and the platform stands in the middle.
This pattern appears across well-known platforms like Airbnb, Booking, Uber, Etsy and Eventbrite, but just as much in smaller learning, wellness, consulting, creator and freelance environments.

The new Third Payment Services Deal (PSD3) and Payment Services Regulation (PSR) package aims to change this by increasing 𝘁𝗿𝗮𝗻𝘀𝗽𝗮𝗿𝗲𝗻𝗰𝘆 𝗮𝗻𝗱 𝗮𝗰𝗰𝗼𝘂𝗻𝘁𝗮𝗯𝗶𝗹𝗶𝘁𝘆: PSPs will face liability for weak fraud controls (including impersonation scams), mandatory name–IBAN checks will block mismatched payments, open-banking obstacles will be removed, human support in fraud handling becomes required, and receiving PSPs must freeze suspicious inflows targeting mule accounts.

But the core insight remains:
𝘆𝗼𝘂𝗿 𝗽𝗹𝗮𝘁𝗳𝗼𝗿𝗺’𝘀 𝗰𝗼𝗺𝗽𝗹𝗶𝗮𝗻𝗰𝗲 𝗶𝘀 𝗻𝗼𝘁 𝗲𝗻𝗼𝘂𝗴𝗵 𝗶𝗳 𝘁𝗵𝗲 𝗿𝗲𝘀𝘁 𝗼𝗳 𝘁𝗵𝗲 𝗽𝗮𝘆𝗺𝗲𝗻𝘁 𝗰𝗵𝗮𝗶𝗻 𝗶𝘀𝗻’𝘁 𝗮𝗹𝗶𝗴𝗻𝗲𝗱, 𝘁𝗿𝗮𝗻𝘀𝗽𝗮𝗿𝗲𝗻𝘁 𝗮𝗻𝗱 𝗰𝗮𝗽𝗮𝗯𝗹𝗲 𝗼𝗳 𝗺𝗲𝗲𝘁𝗶𝗻𝗴 𝗶𝘁𝘀 𝗿𝗲𝘀𝗽𝗼𝗻𝘀𝗶𝗯𝗶𝗹𝗶𝘁𝗶𝗲𝘀.

The full article in the FD is in Dutch. If you would like to read the full article in English, just send an e-mail to info@acginter.com with “The weakest digital link – English article” as subject and we will be happy to send it to you!