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.

NA

Question 2: Do you agree with the EBA’s assessments on stress testing and the options it considered and progressed or discarded, and the requirements proposed in Guideline 4? If not, please provide your reasoning.

NA

Question 3: Do you agree with the EBA’s assessments on monitoring? If not, please provide your reasoning.

NA

Question 4: Do you agree with the EBA’s assessments on obstacles, the options it considered and progressed or discarded, and the requirements proposed in Guideline 5? If not, please provide your reasoning.

Yes, we agree with the EBA’s assessments on obstacles. The Panel believes that there are considerable security advantages to consumers from redirection i.e. where a consumer using an AISP/PISP is redirected to their ASPSP’s website to enter their credentials directly. This enables them to share access to their account for the use of AISP/PISP services without having to share their login credentials with the AISP/PISP.

We are aware that there has been pressure on the EBA from some AISPs, PISPs and industry groups to declare all redirection an obstacle. We believe that this would be wholly counter to the spirit of PSD2, which is about offering consumers choice of services while improving security and standards of authentication. Consumer choice and empowerment are welcome, but this should not be at the expense of security. We strongly urge the EBA to retain Guideline 5 as it stands.

Question 5: Do you agree with the EBA’s assessments for design and testing, the options it considered and progressed or discarded, and the requirements proposed Guideline 6? If not, please provide your reasoning.

NA

Question 6: Do you agree with the EBA’s assessment for ‘widely used’, the options it considered and discarded, and the requirements proposed Guideline 7? If not, please provide your reasoning.

NA

Question 7: Do you agree with the EBAs assessment to use the service level targets and statistical data for the assessment of resolving problems without undue delay, the options it discarded, and the requirements proposed Guideline 8? If not, please provide your reasoning.

NA

Question 8: Do you agree with the proposed Guideline 9 and the information submitted to the EBA in the Assessment Form in the Annex? If not, please provide your reasoning.

NA

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?

NA

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.

NA

Name of organisation

Financial Services Consumer Panel