In general we support the idea for a new mandatory exemption on this point, given the fragmented and non-uniform applications of art. 10 RTS SCA across Europe and the undesired consequences thereof for customer journeys. We appreciate the newly struck balance in security, customer convenience, uniformity, adoptability and operational implementability.
Rabobank has in the past informally and occasionally voiced an even longer timeline than the proposed 180 days to be acceptable from a balanced risk management and customer ease perspective; therefore the 180 days timeline is favourable, provided that the timeline for direct access (i.e. not via an AISP) is also extended to 180 days. This parity, while maintaining the possibility for a shorter timeline for duly justified reasons, is important for the recognisibility and trust for PSUs and to maintain a level playing field.
A (6-1=) 5 months implementation timeline for ASPSPs should suffice in our view.