Response to consultation on the Guidelines on the conditions to be met to benefit from an exemption from contingency measures under Article 33(6) of Regulation (EU) 2018/389 (RTS on SCA & CSC)
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2. Additionally in paragraph 24 it is stated that CA should check the highest level of availability of any of the best performing PSU interfaces – according to the RTS on SCA the availability of users interface should not be worse than for clients of given ASPSP, not the best one possible.
3. Due to the fact that in majority of cases the mobile channel is a channel with lower usability in relation to the basic channel (which is online banking) in PKO Bank Polski view mobile channel does not indicate the availability of electronic banking for PSU. This is defined by the availability of the “master” channel, i.e. online banking. Therefore it is recommended to take into account the availability indicators of the selected channel, i.e. internet banking (unless that ASPSP is mobile-only).
Question 1: Do you agree with the EBA’s assessments on KPIs and the calculation of uptime and downtime and the ASPSP submission of a plan to publishing statistics, the options that EBA considered and progressed or discarded, and the requirements proposed in Guideline 2 and 3? If not, please provide detail on other KPIs or calculation methods that you consider more suitable and your reasoning for doing so.
1. PKO Bank Polski feels concerned that publishing KPI’s and quarterly statistics on availability and performance of ASPSPs brings a new risk of this data being used by others to carry out, for example an attack on the host and evaluation of effectiveness of these attacks.2. Additionally in paragraph 24 it is stated that CA should check the highest level of availability of any of the best performing PSU interfaces – according to the RTS on SCA the availability of users interface should not be worse than for clients of given ASPSP, not the best one possible.
3. Due to the fact that in majority of cases the mobile channel is a channel with lower usability in relation to the basic channel (which is online banking) in PKO Bank Polski view mobile channel does not indicate the availability of electronic banking for PSU. This is defined by the availability of the “master” channel, i.e. online banking. Therefore it is recommended to take into account the availability indicators of the selected channel, i.e. internet banking (unless that ASPSP is mobile-only).