Response to consultation paper on the draft revised Guidelines on major incident reporting under PSD2

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Q1. Do you agree with the change proposed in Guideline 1.4 to the absolute amount threshold of the criteria ‘Transactions affected’ in the higher impact level?

Yes, we do.

Q2. Do you agree with the changes proposed in Guideline 1.4 to the assessment of the criteria ‘Transactions affected’ and ‘Payment service users affected’ in the lower impact level, including the introduction of the condition that the operational incidents must have a duration longer than one hour?

Yes, we do.

Q3. Do you agree with the inclusion of the new criterion ‘Breach of security measures’ in Guidelines 1.2, 1.3 and 1.4?

Yes, we do.

Q4. Do you agree with the proposed changes to the Guidelines aimed at addressing the deficiencies in the reporting process?

Yes, we do.

Q5. Do you support the introduction of a standardised file for submission of incident reports from payment service providers to national competent authorities? If so, what type of structured file format would you support (e.g. “MS Excel”, “xbrl”, “xml”) and why?

Yes, we do. We suggest an excel file because it is easy to compile.

Q6. Do you agree with the proposed changes to Guidelines 2.4, 2.7, 2.12, 2.14, and 2.18 that are aimed at simplifying the process of reporting major incidents under PSD2?

Yes, we do.

Q7. Do you agree with the proposed changes to the templates in the Annex to the Guidelines?

Yes, we do.

Name of the organization

Nexi Payments S.p.A.