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?

We strongly support the proposal. As a Cloud Accounting software, using the service of an AISP, we propose our 15.000 customers (Businesses) an access to their bank movements on a daily basis. The collection of bank movements must be quick and simple for our clients. The SCA imposed continually by some banks is a real pain for them. They do not understand why, if the AISP is certified, a permanent SCA should be imposed.

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

We support it for the same reasons as above.

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?

We support it. Our AISP must must have a suffisant time to implement the change and make the test to avoid a loss of service / data for our clients.


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