Submission #12

Smart Payments Association

Do you prefer for the EBA guidelines a. to enter into force, as consulted, on 1 August 2015 with the substance set out in this consultation paper, which means they would apply during a transitional period until stronger requirements enter into force at a later date under PSD 2 (i.e. a two-step approach); or to anticipate these stronger PSD 2 requirements and include them in the final guidelines under PSD 1 that enter into force on 1 August 2015, the substance of which would then continue to apply under PSD 2 (i.e. a one-step approach).

Please find it attached the SPA position. SPA considers that Solution b) is preferable

Upload files EBAconsultationv01.docx

Name of organisation Smart Payments Association