Response to consultation paper on the draft revised Guidelines on major incident reporting under PSD2

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Q1. Do you agree with the change proposed in Guideline 1.4 to the absolute amount threshold of the criteria ‘Transactions affected’ in the higher impact level?

yes. But what you could further assess is impact by payment type. E.g. impact is rather different if the payment can be sent out as instant payment or as SEPA payment. If SEPA payment does not go out from the bank in one cycle but next, there is no impact to a customer but due to the amount can be interpreted as reportable.

Q2. Do you agree with the changes proposed in Guideline 1.4 to the assessment of the criteria ‘Transactions affected’ and ‘Payment service users affected’ in the lower impact level, including the introduction of the condition that the operational incidents must have a duration longer than one hour?


Q3. Do you agree with the inclusion of the new criterion ‘Breach of security measures’ in Guidelines 1.2, 1.3 and 1.4?


Q4. Do you agree with the proposed changes to the Guidelines aimed at addressing the deficiencies in the reporting process?


Q5. Do you support the introduction of a standardised file for submission of incident reports from payment service providers to national competent authorities? If so, what type of structured file format would you support (e.g. “MS Excel”, “xbrl”, “xml”) and why?

for us current standard MS Excel file works good. We do not support xbrl or xml file format, because it requires additional development to enable person to insert data in the file as this type of report cannot be created automatically.

Q6. Do you agree with the proposed changes to Guidelines 2.4, 2.7, 2.12, 2.14, and 2.18 that are aimed at simplifying the process of reporting major incidents under PSD2?


Q7. Do you agree with the proposed changes to the templates in the Annex to the Guidelines?


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