The EBA Opinion on the implementation of the RTS on SCA and CSC (EBA-Op-2018-04) contains a Table entitled “Main requirements for dedicated interfaces and API initiatives” and Row 9 refers to the possibility of “cancelling an initiated transaction in accordance with PSD2, including recurring transactions”. Please clarify that these requirements will not apply to single payment transactions initiated by Payment Initiation Service Providers (PISPs) for immediate execution?
Article 80(2) PSD2 states that a payment transaction initiated by a PISP cannot be revoked by the Payment Services User (PSU) after giving consent to the PISP to initiate the payment transaction Table 1 in the EBA Opinion (EBA-Op-2018-04) suggests that PISP initiated transactions may be revoked/cancelled after initiation and the Application Programming Interface (API) must accommodate that functionality.
According to Article 80(2) of Directive 2015/2366/EU (PSD2) “where the payment transaction is initiated by a payment initiation service provider or by or through the payee, the payer shall not revoke the payment order after giving consent to the payment initiation service provider to initiate the payment transaction or after giving consent to execute the payment transaction to the payee".
It follows that, provided the payer consented to the initiation by the payment initiation service provider, a single payment transaction initiated by the payment initiation service provider for immediate execution cannot be revoked. This is without prejudice to Article 80(5) PSD2 which sets out in which conditions transactions can be still cancelled after the time limits in Article 80(1) to (4) PSD2.
In line with the Opinion of the European Banking Authority on the implementation of the RTS on SCA and CSC (EBA-Op-2018-04), account servicing payment service providers should ensure that the interface provided to payment initiation service providers allows for the possibility of cancelling an initiated transaction, including payment transactions for immediate execution as well as future-dated and recurring transactions where these can be cancelled according to PSD2 e.g. if agreed between the payment service user and the relevant payment service providers
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