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 hereby make use of the European Banking Authority's (EBA) consultation on amending its technical standards for strong customer authentication and secure communications. We strongly recommend not only providing for a 90-day account access exemption, but also advocating for a further strong customer authentication (SCA) exemption in the EU Commission Delegated Regulation (EU) 2018/389. If, in implementation of the SCA requirement of PSD II, a PIN pad is required to be installed on the charging station, this will have considerable consequences for the costs and installation space espe-cially of AC charging stations, as described below.
See attachment sent by email to eba.consultation@eba.europe.eu on 25th November 2021

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

See answer to Q 1

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?

See answer to Q 1

WHAT TYPE OF INSTITUTION OR STAKEHOLDER DO YOU REPRESENT?

other - please specify

Please specify, if you selected "other type of institution"

Manufacturers and operators of charging stations

Name of the organization

ABB ABL bender chargecloud chargepoint ecotap EnBW E.ON EV Box has.to.be LEM Smartlab swarco TotalEnergies Webasto Wirelane etc.