See the input of The Dutch Payments Association.

Furthermore we would like to add some remarks.
Standardisation:
• We would like to stress a need for a single technical standard for implementation of the secure communication relays between the PSPs [e.g. a standardized set of APIs]
• We would like to strongly advise EBA to standardize both which transaction-related information should be exchanged and the formats and rules on which it can be exchanged between the PSPs [e.g. for the purposes of forwarding transaction-related information by transaction initiation].
• We believe that a dedicated EU body to maintain and develop the standards further is required.

We believe that these topics require further discussion.

See the input of The Dutch Payments Association.

Furthermore:
In our view, there are innovative approaches to organise access to account for PIS and AIS providers. We believe that a beneficial approach is to separate the process of PSU enrolment into AIS / PIS providers and authorisation of the AIS / PIS providers at ASPSP – on behalf of the PSU, - from the process of regular PSU authentication at a PSP in order to perform a transaction
• We advocate it should be possible for PSU to grant a long term authorisation for AIS / PIS provider to access ASPSP, for instance during the enrolment process
• We are convinced that using RESTful APIs and authorisation based on e.g. oAuth will allow for secure, effective and flexible implementation of such approach
• We believe that AIS/PIS providers should be allowed to issue their own security credentials

We believe that these topics require further discussion.