On 19 December 2017, the ACM published a more specific study on the position of fintechs in the payment services system. Banks have information that fintechs require in order to be able to offer their services. One of the ACM’s conclusions is that there is a genuine risk of foreclosure of these new providers.

According to the ACM, this means that banks may have a dominant position with regard to this type of information. Since banks (potentially) compete with front-end fintechs, the ACM sees a genuine risk that these companies will be excluded.