What New Regulations Mean for Payment Infrastructure Modernization

The European payments landscape is entering one of its most significant regulatory transitions in decades. With SEPA 2.0 and PSD3 converging around 2026, banks and payment service providers face more than updated rulebooks—they face a fundamental shift in how payment systems must be designed, operated, and evolved. 

These regulations are not simply adding new obligations. They are reshaping expectations around real-time processing, traceability, authentication, and risk management, forcing engineering teams to rethink legacy architectures that were built for batch processing and post-factum compliance. 

So why does compliance-driven development is becoming a defining capability for modern banking platforms.?

From Regulatory Requirements to Engineering Constraints 

Historically, compliance in payments was handled through processes layered on top of existing systems. Transactions were processed first, and regulatory checks, reporting, and audits followed later. That approach no longer holds. SEPA 2.0 pushes for real-time or near-real-time payment processing and settlement, while PSD3 raises the bar on customer authentication, fraud prevention, liability, and transparency across the entire payment lifecycle. Together, they turn compliance into a runtime concern. 

Engineering teams must now assume that every payment, API call, and authentication decision may need to be explained, replayed, and audited—often instantly. 

Traceability Becomes a First-Class Architectural Requirement 

One of the strongest signals coming from SEPA 2.0 and PSD3 is the emphasis on traceability. Regulators increasingly expect institutions to provide a complete, end-to-end view of how a payment was initiated, processed, enriched, authorized, and settled. This level of transparency cannot be retrofitted easily. It requires architectures that propagate correlation identifiers across services, preserve event histories, and support replay and forensic analysis. Event-driven systems, immutable logs, and structured observability become essential building blocks. 

Traceability is no longer something compliance teams request after an incident—it must be engineered into the system by design. 

Real-Time Risk and Fraud Detection Under PSD3 

PSD3 significantly tightens expectations around fraud prevention and risk management, particularly for instant and open payments. Batch-based AML or fraud checks that run minutes or hours after a transaction are no longer sufficient. 

Modern payment infrastructures must evaluate risk before or during authorization, often within strict latency budgets. This pushes teams toward streaming architectures where transaction events feed real-time risk engines, combining rules, behavioral signals, and machine learning models. 

From an engineering perspective, this means building pipelines that can score transactions deterministically, explain decisions, and fail safely—without introducing unacceptable delays into payment flows. 

Strong Customer Authentication Moves Toward Context-Aware Models 

While SCA is not new, PSD3 accelerates the move away from static, one-size-fits-all authentication. Regulators increasingly recognize that security should be proportional to risk, not enforced blindly at every step. Technically, this shifts authentication from a single step into an orchestrated decision flow. Device trust, behavioral patterns, transaction context, and historical activity all contribute to whether additional authentication is required. 

Engineering teams must design authentication platforms that can integrate multiple identity providers, support modern methods like passkeys and biometrics, and remain fully auditable. Authentication becomes a system in its own right, not just a login screen. 

Compliance Pipelines Replace Compliance Checklists 

One of the most profound changes driven by PSD3 is the expectation that compliance is continuous. Regulators increasingly scrutinize how systems are built, deployed, and operated—not just their end results. This leads to the emergence of compliance pipelines, where regulatory checks are embedded directly into CI/CD and runtime workflows. API changes are validated for backward compatibility, security controls are tested automatically, and audit artifacts are generated as part of normal system operation. 

For engineering teams, this blurs the line between development and compliance. Code quality, system design, and regulatory adherence become inseparable. 

Legacy Systems Under Pressure 

Many banks still rely on core systems designed for batch settlement, delayed reconciliation, and limited observability. SEPA 2.0 and PSD3 expose the limits of these architectures. 

Full replacement is rarely feasible. Instead, banks are adopting incremental modernization strategies: introducing event-driven layers around legacy cores, decoupling compliance logic from transaction processing, and gradually shifting critical flows to real-time pipelines. 

This approach allows institutions to meet regulatory expectations without destabilizing existing operations—but it requires careful architectural planning and execution. 

Why Regulation Is Accelerating Architectural Change 

Contrary to popular belief, regulation is not slowing innovation in payments—it is accelerating it. SEPA 2.0 and PSD3 effectively mandate capabilities that align with modern engineering best practices: real-time processing, observability, automation, and resilience. 

Banks that treat regulation as a forcing function for modernization will emerge with more scalable, transparent, and competitive platforms. Those that attempt to patch compliance onto outdated systems will struggle to keep pace. 

How OceanoBe Supports Compliance-Driven Modernization 

At OceanoBe, we work with banks and fintechs where compliance is not an afterthought, but a core design constraint. Our teams help translate regulatory requirements into concrete engineering solutions. 

• We support clients in: 
• designing event-driven payment architectures aligned with SEPA 2.0 
• embedding traceability and auditability into core flows 
• building real-time fraud and risk scoring pipelines 
• orchestrating modern SCA and identity workflows 
• integrating compliance checks into CI/CD and runtime systems 

Our experience across banking, payments, and fintech allows us to bridge the gap between regulation and implementation—turning compliance into a competitive advantage rather than a bottleneck. 

2026 Is an Engineering Deadline 

SEPA 2.0 and PSD3 are not abstract regulatory milestones. They are concrete deadlines that demand architectural change. By 2026, payment platforms must be real-time, traceable, secure, and continuously compliant by design. For engineering teams, this represents both a challenge and an opportunity. The institutions that invest now in compliance-driven architecture will be better positioned to scale, innovate, and earn trust in an increasingly real-time financial ecosystem. 

In modern payments, compliance is no longer something you prove after the fact. It’s something you build into the system—line by line.