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 if the security aspect has been validated by experts.

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

Same answer : we agree to all simplifications that will relieve our users of constraints, if these simplifications do not endanger their bank account security.
Our customers do not understand why they are being asked to renew their SCA , and they are bored.

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?

NA

WHAT TYPE OF INSTITUTION OR STAKEHOLDER DO YOU REPRESENT?

technical service providers

Name of the organization

ISAGRI