Bitkom welcomes EBA’s initiative to harmonize the practice of applying SCA exemptions under Article 10 PSD2. To oblige ASPSPs to apply SCA exemptions for AISPs reduces unnecessary frictions and enables AISPs to provide the same quality of services across the EU. By and large, AISPs are generally granted SCA exemptions for 90 days by ASPSPs in Germany. The German NCA determined early on that SCA exemptions are a prerequisite for the PSD2 API design, which helps AISPs to provide convenient and secure services to their consumers. Thus, the proposed introduction of Article 10(a)(1) is an important addition toward creating a level playing field under a common timeframe for all EU member states.
In general, Bitkom calls for a larger debate in the context of the PSD2 review to revisit certain aspects including security standards and their corresponding RTSs as well as to align the needs and interests of consumers and a growingly diverse set of market participants in the field account information and payment services.