Response to discussion on RTS on strong customer authentication and secure communication under PSD2
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Dynamic linking should be understood as applied to the messages being sent, so that compromise in the communication media is protected, not necessarily internally to the device.
Two objectives are fulfill: the device is acknowledged and the message can not be compromised if captured out the device.
Thus, the use of such key may be regarded as no necessarily preventing the independence between two criteria."
1. With respect to Article 97(1) (c), are there any additional examples of transactions or actions implying a risk of payment fraud or other abuses that would need to be considered for the RTS? If so, please give details and explain the risks involved.
Registering payment details on commercial web sites, online signing of e-mandates, enrolling on third party providers...2. Which examples of possession elements do you consider as appropriate to be used in the context of strong customer authentication, must these have a physical form or can they be data? If so, can you provide details on how it can be ensured that these data can only be controlled by the PSU?
Data encryption keys downloaded or incorporated on devices that are used to electronically sign, digital certificate ...3. Do you consider that in the context of “inherence” elements, behaviour-based characteristics are appropriate to be used in the context of strong customer authentication? If so, can you specify under which conditions?
Yes, although those behavior-based patterns can also be considered as basis for exemptions.4. Which challenges do you identify for fulfilling the objectives of strong customer authentication with respect to the independence of the authentication elements used (e.g. for mobile devices)?
The use of a one time use passwords sent to the phone should not be used alone5. Which challenges do you identify for fulfilling the objectives of strong customer authentication with respect to dynamic linking?
Dynamic linking should also apply when a OTP is given, once the PSP takes note of the details of the operation, not necessarily linking both things on the same message.Dynamic linking should be understood as applied to the messages being sent, so that compromise in the communication media is protected, not necessarily internally to the device.
6. In your view, which solutions for mobile devices fulfil both the objective of independence and dynamic linking already today?
The downloading of a private key to the app so that communication is protected by a dynamic seal" or "signature" being added to the message.Two objectives are fulfill: the device is acknowledged and the message can not be compromised if captured out the device.
Thus, the use of such key may be regarded as no necessarily preventing the independence between two criteria."