The KPIs proposed allow time span measurements per channel but overlooked qualitative measurements such as PSU’s convenience (number of screen or click) and abandon rate that are key factors for enabling a dedicated interface being widely used. They also do not address the need of benchmarking with customer facing interfaces, if used by PSUs.
The identification of the channel such as online banking and mobile banking must be available in the dataset of the dedicated interfaces and reported accordingly to the CA within the PKI. This information is critical from a risk based analysis but also for assessing the performance of the dedicated interfaces with all channels and therefore defining if it allow PSUs to really widely use the dedicated interface online and in-store with the strong authentication method proposed by the ASPSP.
Therefore there is a lack of
• Recommendations enabling the analysis and identification of possible obstacles preventing the use by PSP of the credentials issued by the ASPSP.
• comparison/benchmarking criteria of performance of ASPSPs dedicated interface with PSPs
• measurement of errors and complains with the ASPSP dedicated interfaces per channel
• Measurement of services (selection of accounts, support of trusted beneficiary,…) and convenience offered by the dedicated interface to support TPPs for implementing the API(s)
• Measurements of ASPSP options with the implementation of dedicated interfaces if they vary from the specifications and/or have different end points
• Measurements of dataset completeness for mandatory and optional fields
EuroCommerce believe that contingency plan shall be included in the stress testing, with ASPSP facing attacks such as DOS (denial of service), in order to provide continuity of services with dedicated interfaces in degraded environments.
EuroCommerce considers the ASPSP’s monitoring obligations defined in article 32 of the RTS as key criteria for performance, wide usage and availability allowing exemptions by CA.
If ASPSPs do not comply with monitoring requirements to allow CA assessing the exemption, CA would not be able granting any exemption
EuroCommerce considers dedicated interfaces supporting only redirection as an obstacle as this access method creates unnecessary frictions to PSU in non-browser based setups and also restrict innovation of PSP.
Redirection implies PSU being moved from one interface to another and back again which is confusing and time consuming. Currently customers enjoy only one click payment experiences or even no click payment journey.
EuroCommerce recommends each technical specification support and encourages ASPSP to propose a common set of connection, security, functions and services avoiding any unnecessary fragmentation in Europe per specifications as currently observed. A conformance process shall be developed per specification.
The confirmation by yes /no of the execution of the transaction is critical for merchant releasing the goods and services. The support of real time confirmation is critical for PSU and should be clearly available to CAs, PSPs and PSUs.
EuroCommerce considers a dedicated interface as widely used only if it is continuously used by PSUs. Just making an interface public does not preclude it is available for a wide usage. A widely usage should consider the channels and the usage by the PSU in a regular basis and omni-channel.
Information on resolution of problems identifying PSU and PSP complains shall be part of the CA approach for giving exemptions allowing a transparent and level playing field.
EuroCommerce welcomes any harmonisation in assessment process for exemption
EuroCommerce foresees risks of delay and fragmentation per ASPSP as APIs specifications do not define precise guideline for basic PIS and AIS services. Variance and options in implementations may create unnecessary risks and confusions.
EuroCommerce welcomes any SEPA wide harmonisation of dedicated interfaces and services which would require more detailed recommendations and guidelines. Further clarifications and harmonisations of well-functioning and widely used dedicated interfaces shall integrate the PSU experience and convenience in an omni-channel perspective, end to end with smart authentication methods