Submission #1252

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The European Digital Payments Industry Alliance (EDPIA)

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?

The European Digital Payments Industry Alliance (EDPIA) supports the new mandatory exemption.

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

The European Digital Payments Industry Alliance (EDPIA) supports extending the renewal timeline to 180-days particularly as a practical step that can be implemented in the near future. One general challenge that may be worth considering is related to the workflow and exchange of information between third parties and account providers. Our membership is providing more technical input on this and other points, and would be happy to discuss it in more detail.

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?

The European Digital Payments Industry Alliance (EDPIA) believes that 6-months is a realistic implementation timeline.

WHAT TYPE OF INSTITUTION OR STAKEHOLDER DO YOU REPRESENT? industry associations

Name of the organization The European Digital Payments Industry Alliance (EDPIA)