# PSD3 Article 12 — Record-keeping

Textual state: amended_substantial. 21 words changed

- Compared text: Council position at first reading (Council document 8535/26) — not yet law.
- Compared against: Council document 8222/26 — superseded.
- Classification is mechanical; method: https://paymentslaw.eu/method/
- Editorial review state: not_assessed. Editor's notes are selective, not a complete assessment.

Word-level diff for each step, earlier → later edition: `{+text+}` was inserted, `[-text-]` was deleted.

## Step 1 · Commission proposal (2023) to Council compromise text (April 2026)

Article 12 → 12. Textual state: unchanged. No text changes from the 2023 proposal.

- Editorial review state: not_assessed.

### Unnumbered text

Member States shall require payment institutions to keep all appropriate records for the purpose of this Title for at least 5 years, without prejudice to Directive (EU) 2015/849 or other relevant Union law. When such records include personal data, the payment institution shall not keep those records for longer than necessary for the purpose of this Title. Where there is a withdrawal of the authorisation of the payment institution in accordance with Article 16, records that include personal data shall not be kept more than 5 years after the authorisation has been withdrawn.

## Step 2 · Council compromise text (April 2026) to Council position at first reading (October 2026)

Article 12 → 12. Textual state: amended_substantial. 21 words changed

- Editorial review state: not_assessed.

### Unnumbered text

Member States shall require payment institutions to keep all appropriate records for the [-purpose -]{+purposes +}of this Title for at least [-5 -]{+five +}years, without prejudice to Directive (EU) 2015/849 {+of the European Parliament and of the Council +}or other relevant Union law. When such records include personal data, the payment institution shall not keep those records for longer than {+is +}necessary for the [-purpose -]{+purposes +}of this Title. Where there is a withdrawal of the authorisation of the payment institution in accordance with Article [-16, -]{+16 of this Directive, +}records that include personal data shall not be kept {+for +}more than [-5 -]{+five +}years after the authorisation has been withdrawn.