For (international) corporates the management of their bank accounts (initiating payments and viewing account information) poses significantly more risk compared to private individuals and SME businesses.  In a corporate client environment, such management entails risks that are exponentially higher due to:

• the high number (millions) of payment transactions and (sensitive)(personal) payment data records;
• the high numbers of users/employees with payment initiation and/or viewing rights;
• corporates using multiple (electronic) channels and payment instruments;  
• corporates having many bank accounts in many currencies in multiple countries, often with multiple (Pan-) European ASPSPs; and
• the setup of their account and liquidity management may be subject to overarching cash management facilities and/or payment factories (centralisation of operations).

This results in risk being substantially higher for corporates (e.g. utility or telco companies, government/public agencies, tax authorities, media companies) compared to the context of a private individual or smaller business clients. To manage such risks corporates have comprehensive risk policies to identify, assess, and mitigate potential risks associated with payment processing. These risks include, but are not limited to, fraud, data breaches and business continuity. The factual day-to-day management of accounts is performed by users/employees appointed by the corporate or, in case of centralisation of account management, by group companies. Detailed proxy matrices are implemented by corporates with their ASPSPs to manage risk, particularly fraud and unauthorised access to sensitive company information and personal data included in transaction information. Authority/proxy to users is granted in accordance with the local (civil and corporate) law requirements of the country of incorporation of the corporate/accountholder.

Proxy matrices generally are very detailed, they cater for users to have access to one/more/all accounts and generally include limitations/conditions: joint or several (levels of) authorisation, authorisation up to certain amounts, access through one or more electronic channels/payment instruments, local/regional/global authority and use of certain payment products. A user can have access to one or more electronic channels/payment instruments with different transaction/daily limits applying to each of them. The corporate’s governance framework/policy sets the internal rules, however, the relevant controls effectuating such governance framework/policy are (also) implemented through authorisation instruments issued by the corporate’s ASPSPs. For ASPSPs it is paramount to abide by the proxy matrices to prevent the risk of unauthorised payment transactions and/or (personal) data leakage.

With the introduction of Open Banking a new ‘PSD2 channel’ has become available to corporates to manage accounts. Consequently, to manage and control above risks, they may further diversify their proxy matrices and specify if and to what extent a user has authority to manage accounts through third part payment service providers (TPPs). As Open Banking services can be invoked by users through mobile apps, corporates implement further conditions to control which sensitive and personal data may be shared with whom, e.g. by detailing in their proxy matrices which users may have access to (certain) accounts through TPPs without necessarily duplicating the proxy matrix existing for the ASPSP’s proprietary channels.

It is a general principle of law that a corporate has sole discretion how to manage its assets (including bank accounts) and to which users/employees it so grants authority and subject to what conditions. Paragraph 46 of the EBA’s Opinion on obstacles (EBA/OP/2020/10) acknowledges that only certain users may have authority to operate accounts. So, a user may have authority to manage one or more accounts through one or more channels subject to applicable conditions, e.g. different limits may apply for one user: a limit of 1500,- for a card, a limit of 100.000,- for electronic banking and no limit for host-to-host channel.