FEDMA, the Federation of European Direct and Interactive Marketing, represents the data-driven marketing industry. FEDMA stands for 22 national Direct Marketing Associations, directly representing more than 5 000 organisations, and for more than 50 organisations, representing all parts of the value chain in the data-driven marketing industry. Through its many activities, FEDMA is dedicated to building the business of cross-border data-driven marketing, both through its vast network of contacts and businesses within and beyond Europe and by representation within the institutions of the European Union.

The data-driven marketing industry uses personal information and data to effectively match customers’ needs with relevant brand offers. The data-driven marketing industry aims to create and maintain an individual and interactive relationship between businesses, institutions and their customers (both prospective and existing). The data-driven marketing industry allows retail businesses to target people with a personalised message, to generate sales both online and in store in a cost effective way to build long-lasting relationships with customers and raise brand awareness. Therefore, ecommerce and Data-driven marketing industries are very interconnected. This is why, FEDMA encourages the EBA proposed standard to avoid negative effects on the ecommerce sector.

FEDMA calls on policy makers to avoid imposing any measures which would reduce the eCommerce volumes and to avoid channel distortions (offline vs online). FEDMA asks you to bear in mind the consumer experience and the feasibility of certain measures to impact as little as possible ecommerce.

FEDMA has identified three main issues : the blanket approach as proposed by the EBA for Strong Customer Authentication (SCA) (which we do not support), the criteria proposed for the authentication elements are too restrictive and the fact that the regulatory bodies are also auditing Payment Service Providers. Specifically, the blanket approach to SCA risks reducing competition in the market, hamper consumer convenience and restrict the development of the Digital Single Market. FEDMA calls on policy makers to ensure the needed flexibility so that traders can use their knowledge of the consumer and of the market to assess risk (e.g., behavioral data, strong customer authentication via login and data from past purchases, etc.). A clearer risk based approach is needed.

FEDMA members are not sure the dynamic linking process would be the most practical and efficient mechanism for online transactions.

FEDMA questions the EBA approach regarding SCA. FEDMA would rather support a targeted risk based approach and suggests an approach whereby industry best practices are acknowledged.

FEDMA calls for more flexibility of the framework proposed by the EBA, taking more into account a risk based approach.

FEDMA calls for the EBA and policy makers to avoid reducing competition in the market and ultimately creating less favourable conditions for eCommerce. For example, FEDMA questions the limited provision of direct access technology by non-bank third-party payment initiation service providers (TPPs).