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?

It feels like a good idea. As a provider of Expense software, I've had numerous complaints from end users about the frequent authentications required. By end users, I mostly mean companies that sync corporate card transactions with our software in order from their employees to report their expenses.

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

Twice a year seems like a good compromise.

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?

No

WHAT TYPE OF INSTITUTION OR STAKEHOLDER DO YOU REPRESENT?

account information service providers

Name of the organization

Lucca