Guidelines 06/2020 on the interplay of the Second Payment Services Directive and the GDPR

Section 3.3  Conclusion

43 Explicit consent under the PSD2 is different from (explicit) consent under the GDPR. Explicit consent under Article 94 (2) of the PSD2 is an additional requirement of a contractual nature. When a payment service provider needs access to personal data for the provision of a payment service, explicit consent in line with Article 94 (2) of the PSD2 of the payment service user is needed.