For reasons unknown to me, Dutch government still wants to add a Dutch sauce to EU-regulation when implementing these. Yesterday, two lawyers identified this same behaviour of government in the Financieel Dagblad (Onno Brouwer, Kees Schillemans). They noticed that the implementation regime of Regulation 1/2003 de facto withdraws previous exemptions as issued by the competition authority. In the retail payment sector this would mean that the exemption rulings for interchange fee acceptgiro and atm-usage may be immediately up for legal testing.
Apart from their observation, the Regulation 1/2003 holds promises for more competion in local markets. Market players may now take one another to court if they observe collusion/kartels. Interesting enough, this change has not received a lot of attention in the media.
