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 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?

We are the B2B client of a TPP: collecting banking data through AISP’s services is on our critical path to serve our clients (who are consumers and small/medium businesses) and to provide appropriate secured services. Our users therefore need us to continuously gather their data live without their constant intervention. We do agree that the timeline to renew SCA must be extended, and we consider this extension should be way longer than the 180 days proposed. In our opinion, this timeline should be ideally more than one year. On one hand, our users do not understand why they are being asked to renew their SCA and often complain to us that they do not feel the need or the use for it. They do not understand this burden: they do want to be exempted from doing so and see this requirement as a genuine obstacle to the adoption of our services (and therefore meaning those of the AISP). On the other hand, we have never been facing any complaints for fraud cases from our customers/consumers nor registered any case of fraud. Hence, we would suggest to maintain the principle of this extension, and would strongly advise to make it more than one year.

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?



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