Response to consultation on RTS on home-host cooperation under PSD2
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Worldline asks EBA to remove article 10 (1b).
However, the level of detail requested goes, in our opinion, beyond the mandate given in PSD2 Article 29 (6). In Art. 29 (5a), the PSD2 asks EBA to include in the reporting “in particular … the total volume and value of transactions carried out by payment institutions in host member states”.
The long list of reporting requirements in the form proposed in Annex 6 goes way beyond this requirements. Additionally, the consultation paper gives no rationale for the extensive reporting requirements except for “statistical” reasons. There is no intrinsic value of reporting for statistical reasons, there should be a goal, which is not evident in the consultation paper.
Worldline is of the opinion reporting at the proposed level of detail should only be required by the home member state. Home member states CAs should then distribute the relevant reports to host member states CAs if required by them.
Worldline would also like to point out the fact that some of the reporting requirements are already required by other guidelines and would ask EBA to make an effort to reduce duplicate reporting requirements. Examples are the requirements to report fraud transactions (Consultation paper on fraud reporting; EBA/CP/2017/13) and incident reporting (Consultation paper on incident reporting; EBA CP/2016/23).
Worldline asks EBA to remove any duplicate reporting requirements from the form in Annex 6.
Question 4: Do you consider that the approach proposed in Article 10, which gives the host CA discretion to require reporting either from all payment institutions or a characteristic subset thereof, is methodologically robust?
Worldline welcomes the attempt to standardize reporting in order to harmonize reporting to competent authorities across the EU. However, giving competent authorities the possibility to request reporting from only a specific subset of payment service providers is contradictory to the goal of creating a single European payments market and a level playing field across the European Union.Worldline asks EBA to remove article 10 (1b).
Question 5: Do you consider that payment institutions will be able to report the data specified in Article 10 and Annex 5? If not, what obstacles do you see and how could these obstacles be overcome?
Worldline welcomes the attempt to standardize reporting across all member states. Standardized reporting will reduce differences in reporting requirements between different member states, furthering the goal of a harmonized payments market and a level playing field in the EU.However, the level of detail requested goes, in our opinion, beyond the mandate given in PSD2 Article 29 (6). In Art. 29 (5a), the PSD2 asks EBA to include in the reporting “in particular … the total volume and value of transactions carried out by payment institutions in host member states”.
The long list of reporting requirements in the form proposed in Annex 6 goes way beyond this requirements. Additionally, the consultation paper gives no rationale for the extensive reporting requirements except for “statistical” reasons. There is no intrinsic value of reporting for statistical reasons, there should be a goal, which is not evident in the consultation paper.
Worldline is of the opinion reporting at the proposed level of detail should only be required by the home member state. Home member states CAs should then distribute the relevant reports to host member states CAs if required by them.
Worldline would also like to point out the fact that some of the reporting requirements are already required by other guidelines and would ask EBA to make an effort to reduce duplicate reporting requirements. Examples are the requirements to report fraud transactions (Consultation paper on fraud reporting; EBA/CP/2017/13) and incident reporting (Consultation paper on incident reporting; EBA CP/2016/23).
Worldline asks EBA to remove any duplicate reporting requirements from the form in Annex 6.