We are the B2B client of a TPP: collecting banking data through AISP’s services is critical to us in order to provide our services to our customers (who are consumers and small/medium businesses). Our customers/consumers therefore need us to continuously gather their data live without their constant intervention. We do agree that the timeline to renew SCA must be extended, and we think this extension should be way longer than the 180 days proposed. In our opinion, this timeline should be ideally more than one year. On one hand, our customers/consumers simply do not understand why they are being asked to renew their SCA and often complain to us that they do not feel the need or the use for it. They do not understand this burden: they do want to be exempted from doing so and see this requirement as a genuine obstacle to the adoption of our services (and therefore meaning those of the AISP). On the other hand, we have never received any complaints for fraud cases from our customers/consumers and never had any case of fraud. We would therefore suggest to maintain the principle of this extension, and would strongly advise to make it more than one year.
Yes TPP can do it in under 1 month and banks should do it in under 3 months