Response to public hearing on the Consultation paper on the amendment of the RTS on SCA&CSC under PSD2
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PSU should be able to define a custom renewal period between 180 days up to 2+ years. This is required for business use cases: companies holding tens or hundreds of bank accounts just cannot handle the SCA process every 90 or 180 days.
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?
We do agree with this proposal.Q2. Do you have any comments on the proposal to extend the timeline for the renewal of SCA to 180-days?
SCA should be at least 180 days.PSU should be able to define a custom renewal period between 180 days up to 2+ years. This is required for business use cases: companies holding tens or hundreds of bank accounts just cannot handle the SCA process every 90 or 180 days.