Response to consultation on RTS specifying the requirements on strong customer authentication and common and secure communication under PSD2

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Question 1: Do you agree with the EBA’s reasoning on the requirements of the strong customer authentication, and the resultant provisions proposed in Chapter 1 of the draft RTS?

I think that targeted authentication provides a better, more balanced and safer alternative to strong customer authentication. Targeted authentication ensures both a high level of online security and a smooth transaction process for the benefit of European consumers, online merchants and the wider economy. Strong customer authentication would be dangerous for the European e-commerce sector.

Question 7: Do you agree with the EBA’s reasoning on the requirements for common and secure open standards of communication for the purpose of identification, authentication, notification, and information, and the resultant provisions proposed in Chapter 4 of the draft RTS?

By aiming to remain ‘technologically neutral’ and ‘not prescribe the use of a specific industry standard’ however, the draft RTS fails to support the industry by putting in place a standardized framework to restrict further market fragmentation, even if it is true that online merchants face too much fragmentation, especially when operating cross-border. This is a consequence of separate alternative e-payment systems, and requires extensive efforts on integration.

Please select which category best describes you and/or your organisation

[Small and medium-sized enterprises (SMEs)"]"

Please select which category best describes the services provided by you/your organisation

[Other"]"

If you selected "Other", please provide details

E-merchant

Name of organisation

FUGAM