Svensk Handel has strong concerns that the approach of the draft RTS will lead to reduced competition in the market and ultimately less favourable conditions for eCommerce. Svensk Handel fears that as the proposal stands now some of the market players, namely banks, will be in a privileged position over some of the other players such as Payment Initiation Services. Non-bank third-party payment initiation service providers (TPPs) must be allowed to continue using direct access via the customer facing online interfaces of the banks in order to initiate payments on behalf of consumers. This direct access technology is well established and is already transforming the market, allowing innovation and promoting competition to the benefit of e-commerce companies, retailer and ultimately consumers. The final regulatory standards must be amended so as to guarantee the right for TPPs to always use the customer facing online interfaces to initiate payments, rather than, as the current draft does, force TPPs to give up their own IT solution. Svensk Handel urges the European Banking Authority and policy makers not to support any measures which could lead to a reduction in competition.