Response to public hearing on the Consultation paper on the amendment of the RTS on SCA&CSC under PSD2

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Q1. Do you have any comments on the proposal to introduce a new mandatory exemption for the case when the information is accessed through an AISP and the proposed amendments to Article 10 exemption?

As a customer of an AISP with 40,000 active synchronisation, it feels mandatory to remove the previous exemption and to introduce a proportionate SCA relative to the use case of the final customer : even 180 days between 2 SCA is not enough and i will explain why.
Our 40000+ customers use our online platform to do their bookkeeping and annual tax statement. Bookkeeping automation has had a huge step forward thanks to PSD2 : it is one of the most spectacular impact on innovation of PSD2.
However, the customer experience has become awful since the introduction of the frequent SCA. Lets take the customer journey of one of our typical customer : an airbnb renter.
When he discovers that our bookkeeping platform will automates its yearly fiscal statement, he is excited, he becomes a customer, he makes his SCA with its bank account. Then, he will not use the platform until year end when it will be tax time : the account information has to be transmitted during at least 12-14 months to be useful for its year end tax statement.
Instead of having such a clean user experience after he subscribes to our platform AND confirm with an SCA that he want the AISP service all year long ... we will ask him every 3-months to reconnect its bank account. We will ask him a double confirmation with an SCA every time. At the end of the day, the customer will have to confirm 4x2 = 8 time that he is INDEED ok to connect its bank account with our bookkeeping platform : such a bureaucracy to get to its yearly tax statement at the end of the year !!
And if he is late to confirm SCA every 3 months, then he will have some missing transactions. For some banks, he only have 45 days of historical datas. So if he waits more than 45 days after an SCA request, the missing transactions are definitely lost and its tax statement will be wrong !!
Lets say that my customer is in vacation and doesnt check his email, its tax statement will miss transactions and be wrong.
Today, 25% of our 40,000 paying customers are always late in renewing the SCA because its just a nightmare. Yes, they want to do their bookkeeping with us, please stop ask them every 3 or 6 months if they are still OK : of course they are, they are paying the service !!
The new mandatory exemption should propose :
- to be sure that the consumer is OK, a first confirmation after 6 months
- but then, it should be every 12 months to respect the natural frequency of the yearly tax statement.

Please, PSD2 has been a huge step in bookkeeping automation bringing innovation to tens of thausends of small b2b owner. Please, lets come back to a decent user experience.

Q2. Do you have any comments on the proposal to extend the timeline for the renewal of SCA to 180-days?

As explained, regarding the natural timeline of a small b2b owner doing bookkeeping and tax statement thanks to AISP, the target should be every year, so extend to 365 days.
As an exception to be conservatory, the customer could be asked to :
- make a first SCA after the first 6 month period
- then every 12 months

Q3. Do you have any comments on the proposed 6-month implementation timeline, and the requirement for ASPSPs to make available the relevant changes to the technical specifications of their interfaces not less than one month before such changes are required to be implemented?


Name of the organization

Indy SAS