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

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

AFTE supported the implementation of the PSD2, which aimed in particular at the emergence of new players such as AISPs in the payment ecosystem. Thus, we are in favor of the initiative to make the systematic strong authentication exemption for AISPs mandatory.
In order to guarantee a satisfactory level of security for data, a delay of 6 months appears to us as the maximum acceptable for the extension of the exemption of the strong authentication.

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?

AFTE cannot take a position on the implementation timeline required for technical implementation by the ASPS, as treasurers are not aware of all technical aspects required to make this changes available.


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