The paper examines challenges in implementing interoperability requirements in digital markets. Designed to foster innovation and competition in retail payments, interoperability has been central to the EU’s open banking framework under the PSD2. It also plays a key role in the DMA, where interoperability requirements are aimed at supporting innovation and the framework’s goals of contestability and fairness. The paper identifies similarities between the PSD2 and DMA approaches to interoperability and outlines lessons DMA enforcers can learn from the implementation of open banking.
