The EACB welcomes the opportunity to participate in the public consultation on Draft Guidelines on procedures for complaints of alleged infringements of th e Payment Services Directive 2. We would like to c omment first on th e subj ect matter an d scope of application of these Draft Guidelines. According to rationale 10 ’’the Guidelines apply to complaints submitted by PSUs, as defined in PSD2; consumer associations; and other interested parties, with regard to the alleged infringements of PSD2 by PSPs. Some competent authorities may want to allow PSPs, and other entities, to make use of the complaints procedures that will be implemented to comply with these Guidelines, depending on the interpretation of the concept of ‘other interested parties’ at national level. This is why the Guidelines are written in a way that no distinction is made between various types of complainants.” The EACB considers that Account Servicing Payment Services Providers/Payment Services Providers should be considered as “other interested parties” and should be able to use the complaint procedures described in the Guidelines.