Europe's fragmented payment wallet ecosystem
European payment wallets are staging a coup, seizing territory beyond P2P, and marching into the heart of ecommerce and POS, threatening to overthrow the traditional payment, born in the USA, Mastercard and Visa. This evolution, not revolution, reflects both the growing maturity of these players and their ambition to become a one-stop shop payment solution to consumers and merchants. Some of the key players include:
• Vipps (Nordics): Initially a P2P solution, now a dominant force in Norway's digital payments
• TWINT (Switzerland): Evolved from P2P to become the Swiss national digital payment solution
• Swish (Sweden): Sweden's widely-adopted mobile payment system
• Bizum (Spain): Bank-owned solution currently expanding from P2P to merchant payments
• Satispay (Italy): An emerging independent payment network
• Blik (Poland): P2P and online payment system
This coup will not happen overnight or within a few weeks; it will take years, highlighting transformative nature of the change over a long period but not as slow as a Darwinian evolution. One of the challenges that domestic payment wallet initiatives face in their growth ambitions is that they must compete on two fronts, with domestic card schemes and international card networks for POS payments. At the same time, they are increasingly looking to expand beyond their home markets, recognising that scale and cross-border relevance is key for long-term success. This creates a complex strategic dynamic where wallet providers must simultaneously defend and grow their domestic market position while developing capabilities for international expansion.
The Italian market provides an interesting case study of domestic competing approaches. Satispay, as an independent fintech solution, has achieved significant growth with 5 million users and more than 350,000 merchants, competing directly with Bancomat Pay, the mobile payment solution of the Italian domestic card scheme Bancomat. Satispay's aggressive market strategy is particularly clear in its merchant pricing policy - offering zero fees for transactions below €10, with a fixed €0.20 fee for transactions above this threshold. This disruptive pricing approach aims to accelerate merchant adoption, especially among small businesses, though it prioritises market growth over immediate profitability. The simplicity of Satispay's implementation, with options like static QR codes for merchants, further facilitates rapid merchant onboarding. Despite this aggressive strategy, Satispay's network of points of acceptance still represents around 14% of Bancomat's acceptance network, demonstrating the continued acceptance strength of established domestic network.
While domestic mobile wallet solutions have achieved significant penetration in their home markets in Europe, they often struggle to extend their reach across borders.
The Digital Markets Act: A catalyst for change
The European Union's Digital Markets Act (DMA) has emerged as a potential catalyst for both domestic growth and cross-border expansion. Most significantly, the DMA mandates that Apple must provide access to third-party payment providers to iPhone's NFC capabilities, breaking Apple Pay's monopoly over contactless payments on iOS devices.
Bizum is preparing to launch its contactless payment solution utilizing NFC technology in mid-2025, allowing users to make payments directly from their Bizum account or linked bank cards. Vipps has become the first player to seize this opportunity, launching its wallet solution on Apple devices in December 2024. However, the implementation reveals significant hurdles: users must navigate through a cumbersome process to set Vipps as their default payment app on their iPhone. This process highlights the challenges wallet provider will face to drive adoption for payments at POS.
Moreover, the competition with Apple Pay extends beyond simple payment functionality. Apple's wallet offers a comprehensive suite of features including:
• Express transit cards with payment capability
• Event and transit tickets accessible from the locked screen
• Loyalty card storage and linkage
• Rich information integration (instructions, maps, locations)
European wallet providers must not only match these capabilities but potentially exceed them. Integration with the European digital identity framework initiative presents one promising avenue among others, offering a distinctive value proposition that combines payments, identity, and region-specific services. EDC has identified additional value propositions that can be interesting use cases.
EMPSA: unifying through interoperability
The European Mobile Payment Systems Association (EMPSA) is a significant attempt to address market fragmentation through interoperability. With 11 members serving 92 million users and processing 3.2 billion transactions in 2022, EMPSA aims to create a pan-European payment network while preserving local initiatives. Under leadership of chairman Christian Pirkner, EMPSA's vision draws parallels with mobile telecommunications, aiming to replicate the seamless cross-border experience of SIM cards in the realm of digital payments.
EMPSA's technical framework focuses on enabling seamless cross-border QR code payments, allowing users from one country to pay with their local wallet in another country without additional steps. The association has already achieved notable successes, such as implementing roaming agreements between different mobile payment schemes and successfully launching cross-border payments between Bancomat (Italy) and BlueCode (Austria). This practical demonstration of interoperability includes:
• Creating standardised APIs and legal frameworks
• Establishing roaming agreements between schemes
• Implementing a flexible commercial model with default rates
• Developing comprehensive scheme rules covering reserve, capture, cancel, and refund operations
The Discover partnership: A case study in interoperability going beyond QR code
While EMPSA's initial focus has been on QR code interoperability, recent developments suggest a broader strategic vision is emerging. A significant step in this direction was demonstrated in November 2024 when EMPSA member Bluecode announced a strategic partnership with Discover Global Network (DGN), potentially opening new paths for European wallet solutions.
This partnership is particularly noteworthy as it extends beyond QR code capabilities, leveraging DGN's global network to enable NFC functionality. The collaboration provides a technical framework that could serve as a template for other EMPSA members, offering an alternative path to both domestic and cross-border NFC payments.
The partnership's technical framework demonstrates how card-based payment infrastructure can support emerging wallet ecosystems:
Core Infrastructure:
• Integration of DGN's BINs and D-PAS technology for virtual card number creation
• Tokenisation and digital wallet services provided by Idemia as TSP (Tokenisation Service Provider)
• Support for both Android devices and iOS (planned for early 2025)
Processing Capabilities:
• Seamless routing through DGN to EMPSA Bridge for reconciliation
• Conversion of NFC transactions from dual to single message format
• Integration with existing domestic processing systems
Implementation Flexibility:
• Support for multiple wallet deployment models (standalone, bank-embedded, white-labeled)
• Single SDK supporting both QR and NFC capabilities
• Standardised APIs for merchant integration
Most likely fostered by the DMA, this partnership potentially represents a stimulus to the trajectory for EMPSA members and suggests EMPSA's interoperability vision could evolve beyond its initial QR code focus, offering members flexibility in how they approach both local and cross-border payment capabilities.
The technical deployment initiatives observed in the market
The DMA has opened three potential implementation paths for wallet providers to operate at POS, each with distinct implications:
1. Card based wallet: A simple digitisation of a card into a wallet (identical to Apple Pay's model)
2. A2A (account-to-account) NFC: NFC account-to-account payments using instant payment rails (SEPA Inst) triggered from a wallet
3. QR NFC: QR code-based solutions using instant payment rails triggered from a wallet
The technical approach chosen carries significant strategic implications:

Given these distinct technical approaches, the strategic choice for wallet providers depends heavily on their market positioning, existing relationships and consumers’ payment habits. The card-based approach, while seemingly the path of least resistance, requires strong issuer relationships and the ability to offer more attractive commercial terms than the current Apple Pay fee in the EU. Most importantly, this approach maintains the traditional interchange-fee based model.
In contrast, both A2A approaches (NFC and QR) represent a more fundamental disruption to existing revenue streams. These options potentially cannibalise a portion of revenue streams from card transactions, requiring wallet providers to carefully consider how to compensate issuers for this missed revenue. Success with these approaches demands not only technical implementation but also the development of alternative revenue models that can maintain issuer support while delivering the cost benefits of A2A payments.
EPI's Wero: A potential alternative approach?
The European Payments Initiative (EPI) presents a contrasting strategy with its Wero product. Currently operating P2P transfers in France, Germany, Netherlands, and Belgium and with a successful e-commerce proof of concept completed with 1. FC Kaiserslautern’s online store in December 2024, EPI has pursued a consolidation-based approach through acquisitions of iDeal (Netherlands), Payconic (Belgium) and the transition of Paylib's 35 million users in France who will be migrated to Wero before Paylib's discontinuation in early 2025. This approach represents a fundamentally different vision for European payment wallet integration.
Unlike EMPSA's focus on interoperability between existing solutions, EPI seeks to build a unified platform through consolidation. This strategy aims to create a standardised payment solution across multiple European markets, though it faces the challenge of competing with well-established national payment systems.
While EPI's Wero initially launches as a P2P payment solution, its strategic roadmap includes expansion to merchant payments, starting with small retailers and ultimately aiming to enable point-of-sale payments at major retailers. In this event, just like Satispay, EPI will most likely face significant challenges in its home markets dominated by incumbent players such as Cartes Bancaires (France) and Girocard (Germany). Its success may ultimately depend on crucial strategic decisions regarding the wallet roll out covered in the technical deployment section. In a card-based wallet scenario, Wero would become a Cartes Bancaires enabler, in a A2A scenario, Wero would compete directly with Cartes Bancaires. Only time will tell as Wero gathers adoption pace.
Unlike other European payment initiatives, EPI's strength lies in its institutional backing from major European financial institutions. The initiative is supported by many of Europe's largest banking groups, including key players like BNP Paribas, Deutsche Bank, Société Générale and ING. This unique consortium structure, where member banks maintain multiple strategic interests - including some with competing domestic schemes like Cartes Bancaires in France - demonstrates the collective commitment to establishing a pan-European payment solution. This institutional foundation provides EPI with financial resources and technical expertise to conduct complex technical developments and strategic M&A operations across Europe. Such backing positions EPI distinctly from other European payment wallet initiatives that typically rely on more limited resources or single-market support.
Consolidation-based approach vs. interoperability-based approach
The challenge of achieving pan-European payment integration has led to two distinct strategic approaches, each representing different philosophies on how to best unify Europe's fragmented payment landscape:


Implementation models and future strategy
As European payment initiatives evolve, three distinct implementation models have emerged, each offering different approaches to balancing user experience with market integration requirements:
• Single App Strategy (e.g., Swish in Sweden): A standalone app available through app stores
• Banking App Integration (e.g., Blik in Poland): Integration within partner banking apps
• Hybrid Approach (e.g., TWINT in Switzerland): Combination of both standalone and integrated solutions
Industry experts, including Bluecode's CEO, suggest that the single app strategy may be best positioned to leverage the opportunities created by the DMA, particularly regarding default wallet settings. The other approaches, while viable, may face additional complexity in implementation and user adoption.
Success factors for any implementation model include:
• Coordinated messaging across banks and advertising channels
• Streamlined process for changing default wallets
• Integration with domestic card networks
• Combination of QR and NFC capabilities
• Development of compelling use cases that exceed existing alternatives
Future Implications
The European payments market has entered a new era where the payment industry faces a crucial choice between preserving local market characteristics through interoperability or pursuing efficiency through consolidation. However, the strategic discussion should not distract EU players from the immediate opportunity presented by the Digital Markets Act. With this regulation – which came in response from European banks' concerns about US firms' growing control over the POS payment landscape requires concrete action from European players – policymakers in Brussels have created an opportunity for European financial institutions to challenge the dominance of US payment firms.
At Edgar, Dunn & Company, our team of payment experts is focused in navigating the complex EU payment landscape, offering tailored guidance to merchants or payment providers to decode short and long-term strategic opportunities.
The content of this article does not reflect the official opinion of Edgar, Dunn & Company. The information and views expressed in this publication belong solely to the author(s).
Louis is a Manager at the Edgar, Dunn & Company Paris office. He has joined the firm in March 2021 and has graduated with an MBA from ESCP Business school in 2020. Prior to joining EDC, Louis has combined 7 years of experience in the banking and aviation industries. Louis enjoys witnessing the modernisation of payments and payment related processes in B2B ecosystems that drive the ongoing change of the financial institutions landscape. When Louis is not supporting clients in various markets to solve payment problems, he will play competitive golf and plan surfing trips.