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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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.

The transparency surrounding the performance of interfaces is welcome. However, the increasing levels of outages of banking systems contrasts strongly with other digital systems in the non-banking world. Whenever I connect to Google the search facility is there. Recently we have not been able to say the same about online bank accounts owned by TSB, or Visa's payment system. We need to be mindful that the proposed up time KPIs are to the standards of the best in the digital world rather than what is currently happening in the banking and payments world.

Question 9: Do you have any particular concerns regarding the envisaged timelines for ASPSPs to meet the requirements set out in these Guidelines prior to the September 2019 deadline, including providing the technical specifications and testing facilities in advance of the March 2019 deadline?

Yes, it's not clear where each ASPSP is in its journey towards the September or March 2019 deadlines. It would be useful for this to be made visible.

Question 10: Do you agree with the level of detail set out in the draft Guidelines as proposed in this Consultation Paper or would you have expected either more or less detailed requirements on a particular aspect? Please provide your reasoning.

We are more concerned about the practical implementation of PSD2 than guidelines. We have one major concern that is not addressed at the moment. It is about the ease of use of Open Banking payments when compared to existing, in-market payments. Amazon's OneClick sets the bar for consumer expectations. We assume that this payment mechanism ultimately operates under the same Payment Service Regulations as those we are designing to operate under PISP mechanisms. Will OneClick (and any other easy-to-use payment service) have to be de-scoped and made be subject to SCA?

Name of organisation

Flow Fintech Ltd