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

Go back

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?

I am in favor of this exemption.

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

I am not in favor of extending the timeline: 90 days was fine. Additionally, I want AISPs to provide free open APIs to access customers own data.

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?

I want AISPs to provide free open APIs to access customers own data in the 1-month timeframe.

WHAT TYPE OF INSTITUTION OR STAKEHOLDER DO YOU REPRESENT?

consumers and consumers' associations

Name of the organization

Unknown