FROM THE EUROPEAN BANKING FEDERATION:
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EBF Response to European Banking Authority’s Consultation on amending RTS on SCA and CSC
under PSD2 (EBA/CP/2021/32)

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Brussels, 26 November 2021 – The EBF has responded to the European Banking Authority’s Consultation on amending RTS on SCA and CSC under PSD2 (EBA/CP/2021/32).

The EBF acknowledges that the issue of 90-days SCA renewal has widely been raised by AISPs as a particularly problematic aspect of PSD2 implementation and the need of the EBA to explore possible solutions. However, as it is important to balance different market views, we are of the view that a mandatory exemption is not appropriate. The exemption should remain voluntary in order to allow ASPSPs to address any potential increase in risk of fraud as per bank risk appetite, whilst also ensuring flexible legislation that does not stifle innovation and cause unnecessary friction in the customer experience.

Concerning the proposed 6-month implementation timeline, the EBF retains that the implementation period needs to consider that most of the implementation burden is on the ASPSP side. For implementing the mandatory exemption for the case when the information is accessed through an AISP a longer implementation period of one year would be needed. For a solution consisting only of an extension to 180 days for renewing SCA, 6-months after publication in the official journal could be enough.

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