Article 64(2) PSD2 states that a standing order constitutes the PSU’s consent for a series of individual payment transactions. Each execution of a scheduled payment therefore qualifies as a separate “payment transaction” under PSD2.

When an ASPSP offers standing order initiation as a service, it may be available both through the ASPSP’s online banking channel and via dedicated PSD2 interfaces. In the case of the PSD2 channel, the PISP transmits the PSU’s instruction to the ASPSP, which then establishes the standing order within its system. After the standing order is set up, the PISP typically does not receive information about the execution status of individual payment transactions.

This situation raises uncertainty as to whether the obligation to provide information to PISPs applies solely to the standing order setup or also to each subsequent individual payment executed under the standing order.

The setup of the standing order itself constitutes consent for multiple future payments, rather than a payment transaction. Each future debit executed automatically by the ASPSP constitutes a distinct payment transaction under Articles 4(5) and 64 PSD2. In parallel, PSUs are able to view the execution status of these individual payments in online banking channels.

Clarity from the EBA is needed to ensure a harmonized interpretation of PSD2, so that PISPs receive information equivalent to that provided to PSUs, and to clarify whether the execution status of each individual payment under a standing order must be communicated to the PISP.