Submission #193

The Bank Association of Slovenia, Subiceva ulica 2, SI – 1000 Ljubljana, Slovenia

Question 1: Do you agree with the EBA’s reasoning on the requirements of the strong customer authentication, and the resultant provisions proposed in Chapter 1 of the draft RTS? Yes.

Question 2: In particular, in relation to the “dynamic linking” procedure, do you agree with the EBA’s reasoning that the requirements should remain neutral as to when the “dynamic linking” should take place, under the conditions that the channel, mobile application, or device where the information about the amount and the payee of the transaction is displayed is independent or segregated from the channel, mobile application or device used for initiating the payment, as foreseen in Article 2.2 of the draft RTS. Yes.

Question 3: In particular, in relation to the protection of authentication elements, are you aware of other threats than the ones identified in articles 3, 4 and 5 of the draft RTS against which authentication elements should be resistant? Yes.

Question 4: Do you agree with the EBA’s reasoning on the exemptions from the application of Article 97 on strong customer authentication and on security measures, and the resultant provisions proposed in Chapter 2 of the draft RTS? Yes.

Question 5: Do you have any concern with the list of exemptions contained in Chapter 2 of the draft RTS for the scenario that PSPs are prevented from implementing SCA on transactions that meet the criteria for exemption?

Bank 1: We propose that article 8 point 1 ii is excluded from TS: is not good users’ experience.
Article 8 point 1 b i and ii
Article 8 point 2 d i and ii
Rules should be defined by national regulatory body: 50 € have different values in different countries (UK versus Slovenia)

Bank 2: We propose that each PSP has discretionary right to enforce SCA for all transactions regardless that some transactions meet the exemption criteria, especially provision in article 8, paragraph 2d (page 34).

Question 6: Do you agree with the EBA’s reasoning on the protection of the confidentiality and the integrity of the payment service users’ personalised security credentials, and the resultant provisions proposed in Chapter 3 of the draft RTS? Yes.

Question 7: Do you agree with the EBA’s reasoning on the requirements for common and secure open standards of communication for the purpose of identification, authentication, notification, and information, and the resultant provisions proposed in Chapter 4 of the draft RTS?

Article 22, point 5: AIS provider shall receive information only when user is requesting such information.

Question 8: In particular, do you agree that the use of ISO 20022 elements, components or approved message definitions, if available, should be required to ensure the interoperability of different technological communication solutions implemented between PSPs for the provision of AIS, PIS or for the confirmation on the availability of funds? Do you see any particular technical constraint that would prevent the use of such industry standards? Yes - end to end.

Question 9: With regards to identification between PSPs, do you agree that website certificates issued by a qualified trust service provider under an e-IDAS policy would be suitable and allow for the use of all common types of devices (such as computers, tablets and mobile phones) for carrying out different payment services ?

Certificates are acceptable for communication between PSPs, but not between PSPs and client (such as computers, tablets and mobile phones).

Question 10: With regards to the frequency with which AIS providers can request information from designated payment accounts when the payment service user is not actively requesting such information, do you agree that the proposed limit of no more than two times a day achieve an appropriate balance between allowing AISP to provide updated information to their users while not negatively impacting the availability of the ASPSP’s communication interface? If not, please indicate what would be in your view the appropriate frequency and rationale for such frequency.

AIS providers shall receive information only when user is requesting such information.

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The Bank Association of Slovenia, Subiceva ulica 2, SI – 1000 Ljubljana, Slovenia

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Primary objectives of the Association are:
- advocates the common interests of its members in relation to the state and financial authorities
- performs numerous tasks for the benefit of its members which are important for their banking operations
- suggests the uniformity, modernisation, organisation, working technology and standardisation of all financial operations conducted by its members
- provides financial and legal consulting
- engages experts on behalf of its members
- formulates projects in the area of research and development of financial operations and banking
- organises professional training of banking personnel
- organises information and publishing activities

Name of organisation The Bank Association of Slovenia, Subiceva ulica 2, SI – 1000 Ljubljana, Slovenia