MEF has identified via its Global Consumer Survey series the primary importance of trust in enabling mobile money and commerce transactions to grow. We consider that the establishment and maintenance of such trust to be as important as the technical task of protecting user credentials. Hence the risk we identify is that consumers lose such trust as a result either of (a) breaches on a scale or in a quantity that in themselves would not imperil the stability of the payments system and might be considered by the payments industry as physiological or (b) uses of user's personalised security credentials in a manner that may be technically or legally permitted but is not understood or accepted by consumers.

The Mobile Ecosystem Forum is a global trade body representing the broadening ecosystem engaged in mobile content and commerce transactions. We have member led working group activities focused on Consumer Trust, Mobile Messaging and Mobile Money, and whilst we do not currently express a position on the balance between factors requested in this question, we offer MEF and our members’ engagement during the course of the RTS process to help the EBA assess how successfully it is striking this balance as the work proceeds.