Question ID
2018_4339
Legal act
Directive 2015/2366/EU (PSD2)
Topic
Strong customer authentication and common and secure communication (incl. access)
Article
98
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
Regulation (EU) 2018/389 - RTS on strong customer authentication and secure communication
Article/Paragraph
10
Name of institution / submitter
Moneyhub Financial Technology Ltd
Country of incorporation / residence
UK
Type of submitter
Other
Subject matter
90 Day Access via Direct Access
Question

Should any solution which involves direct access, whether as a strategic solution to PSD2, or in relation to the obligation to provide a fallback interface, ensure that Account Information Service Providers (AISPs) can access the interface in the same manner as the dedicated interface, specifically on an ongoing basis and for a maximum of 90 days once the customer has provided consent and authenticated using strong customer authentication (SCA)?

Background on the question

All the Application Programming Interface (API) standards being developed to support the RTS on strong customer authentication and secure communication dedicated interfaces support AISPs gaining access to account information for 90 days a time. Some Account Servicing Payment Service Providers (ASPSPs) seem to think they can avoid this obligation when access "direct access" rather than via a dedicated interface.

Submission date
Rejected publishing date
Rationale for rejection

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Status
Rejected question