OBIE notes the additional clarity proposed by Guidelines 2 and 3. It is clear that the same level of service level objectives, targets, out-of-hours support, monitoring and contingency plans as the ASPSP has in place for its PSU interface must be adopted for its dedicated interface.
However, OBIE considers that the proposed metrics should also include a mechanism by which the actual functionality of an ASPSP’s direct interface can be measured. This could include requiring an ASPSP to provide a more explicit point of comparison between the availability and performance metrics of their dedicated interface versus those that apply to their private APIs and/or PSU direct channel. This could be required in more granular detail than is currently contemplated, and would serve to provide a clear indication as to whether the dedicated interface is actually usable and functioning in an acceptable manner.
OBIE welcomes the EBA’s comments on obstacles. As part of its role as a standards body responsible for developing API technical specifications, OBIE will be producing Customer Experience Guidelines which will provide examples of the ways in which unnecessary delay and friction can be reduced during the customer journey. This includes minimising the number of steps or screens, ensuring language is clear, consistent and concise, and adopting appropriate authentication journeys.
These Guidelines will be complemented by a Checklist which allows ASPSPs and TPPs to self-attest that they are complying with the OBIE Guidelines. The Checklist will form part of the Open Banking Standard Implementation Requirements.
OBIE welcomes the EBA’s draft Guideline 6.4, which requires ASPSPs implementing a market initiative standard to identify the standard, and explain whether, and if so how and why, it has deviated from any standard implementation requirements of the initiative. OBIE will be producing Standard Implementation Requirements designed to promote and ensure consistency and best practice across the ecosystem. These Requirements will include technical specifications that will be assessed using a conformance tool, and Customer Experience Guidelines that will be assessed using a checklist.
The EBA has clarified that the three-month period of widely available / wide usage can run concurrently with the six-month testing period referred to in Art. 30(5). OBIE would welcome further clarity on how, in practice, these two conditions can be fulfilled concurrently and in particular, whether it will be sufficient for an ASPSP to make the interface available for wide usage in a testing environment only, with no use of live market data. OBIE would also welcome clarity on whether this guideline would apply during a transitional period only.