The European Association of Co-operative Banks (EACB) welcomes the opportunity to participate in the EBA consultation on the draft Regulatory Technical Standards (RTS) specifying the requirements on strong customer authentication and common and secure communication under the revised Payment Services Directive (PSD2).
The provisions of PSD2 and the resulting RTS will be implemented in a increasingly complex ecosystem full of diverse service providers. The EACB considers that the RTS should be designed in a way as not to freeze ongoing market developments. For instance, the allocation of liabilities between the different actors involved in a specific payment transaction will need to be properly addressed. While the payments landscape in the European Union is undergoing profound change, the EACB believes that security will always be a must in the field of a payments. The EACB has therefore put forward a proposal to promote a non-mandatory approach to the exemptions from the application of strong customer authentication. As the first port of call to resolve any issue, Account Servicing Payment Service Providers (ASPSP) should remain free to decide whether or not to apply strong customer authentication when the conditions for an exemption are met. Indeed, the ASPSP’s own risk analysis should also be explicitly allowed as an exemption from the application of strong customer authentication. The communication between the different actors involved in a specific payment transaction is essential to ensure its successful execution. Accordingly, the EACB observes with interest the developments affecting the common and secure open standards of communication for the purposes of identification, authentication, notification and information.
For further details, the EACB invites visitors to read the full EACB response by clicking on the link ‘’Download file’’ under the picture.