PSD2: Blessing or curse for the one-man business?
This is the next journal entry on the journey of creating a money-saving product.
With the PSD2 regulation in full force in the Netherlands my understanding is that Account Information Services Providers need to be either registered or licensed with the Dutch Central Bank before being allowed to provide AIS (Account Information Services).
Now, why is this relevant to a lone cowboy building a simple Google Spreadsheets Add-on?
Well, there’s a risk that the service provided by the Add-On might fall under what is seen as providing AIS at which point it might be mandatory to apply to become an AISP.
*cue gasps*
Even though I would not store or have access to any personal- or transactional data the software I build will by definition have to have access to it while retrieving it from the Bunq API, or any other bank I would add integrations to.
If that were the case, this undertaking would suddenly take on a whole different scope if I would wish to publish it publicly under a commercial entity (like a one-man company).
I am currently investigating whether the Add-on would be qualified as providing AIS and have reached out to the innovation hub of DNB (Dutch Central Bank) to see what a next step could look like in my investigate process.
I’m one day in and already such a big surprise shows itself! 😅 If I truly would have to register as an AISP I would be surprised if this would even be possible as a one-man company without a huge investment up-front.
It will be valuable to figure this out, not only for me, but also for anyone else who is interested in hacking together something of value leveraging any Bank’s public API.
PSD2 was introduced to, among other things, drum up more innovation in Europe. In my view, it has already largely succeeded but it will be interesting to see if this kind of grassroots-level one-man innovation would indeed be stifled by the regulation. So is PSD2 a blessing or a curse in this specific instance? Let’s see.
Next journal entry:
