The transparency surrounding the performance of interfaces is welcome. However, the increasing levels of outages of banking systems contrasts strongly with other digital systems in the non-banking world. Whenever I connect to Google the search facility is there. Recently we have not been able to say the same about online bank accounts owned by TSB, or Visa's payment system. We need to be mindful that the proposed up time KPIs are to the standards of the best in the digital world rather than what is currently happening in the banking and payments world.
Yes, it's not clear where each ASPSP is in its journey towards the September or March 2019 deadlines. It would be useful for this to be made visible.
We are more concerned about the practical implementation of PSD2 than guidelines. We have one major concern that is not addressed at the moment. It is about the ease of use of Open Banking payments when compared to existing, in-market payments. Amazon's OneClick sets the bar for consumer expectations. We assume that this payment mechanism ultimately operates under the same Payment Service Regulations as those we are designing to operate under PISP mechanisms. Will OneClick (and any other easy-to-use payment service) have to be de-scoped and made be subject to SCA?