- Question ID
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2025_7674
- Legal act
- Directive 2015/2366/EU (PSD2)
- Topic
- Other topics
- Article
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n.a.
- Paragraph
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n.a.
- Subparagraph
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n.a.
- COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
- Regulation (EU) 2018/389 - RTS on strong customer authentication and secure communication
- Article/Paragraph
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30(3)
- Type of submitter
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Other
- Subject matter
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Requirement for ASPSPs to comply with standardized communication protocols under Article 30(3) of Commission Delegated Regulation (EU) 2018/389
- Question
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Under Article 30(3) of Commission Delegated Regulation (EU) 2018/389, ASPSPs are required to follow communication standards issued by international or European standardisation organisations.
In this context, we seek clarification on whether, when an ASPSP has chosen to adopt a recognized communication standard issued by a European or international standardisation body (such as ISO 20022) for its PSD2 interfaces, the standard is expected to be applied consistently and in accordance with its specifications across all such interfaces, regardless of internal documentation or subsequent clarifications issued by the ASPSP, which may reflect internal implementation approaches rather than the standard itself. - Background on the question
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Article 30(3) requires ASPSPs to ensure that their interfaces follow recognized communication standards issued by international or European standardisation organisations. Recital 21 emphasizes that, to achieve interoperability, the interface should use standards developed by such bodies, be adequately documented, and made publicly available.
ISO 20022 is an example of a widely used European standard to harmonize payment-related messages, including execution status codes. Applying these standards consistently ensures predictability, transparency, and interoperability, enabling third-party providers to process payment information and understand execution status reliably.
In practice, some ASPSPs provide guidance or documentation based on internal approaches, which may not fully align with recognized standards. This can create differences in message interpretation and affect interoperability.
We seek confirmation that, once an ASPSP has chosen to implement a recognized communication standard, the standard should prevail in its entirety and consistently, regardless of internal technical documentation or later clarifications issued by the ASPSP. - Submission date
- Rejected publishing date
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- Rationale for rejection
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This question has been rejected because the issue it raises is out of scope of the Q&A process: it does not relate to the legislative acts referred to in Article 1(2) of the EBA Regulation and their associated delegated and implementing acts, guidelines and recommendations.
- Status
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Rejected question