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Q&As refer to the provisions in force on the day of their publication. The EBA does not systematically review published Q&As following the amendment of legislative acts. Users of the Q&A tool should therefore check the date of publication of the Q&A and whether the provisions referred to in the answer remain the same.

Please note that the Q&As related to the supervisory benchmarking exercises have been moved to the dedicated handbook page. You can submit Q&As on this topic here.

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List of Q&A's

Home / host cooperation

Should banks notify only National Competent Authorities (NCAs) of the home Member State when they use Strong customer authentication (SCA) exemptions on Secure corporate payment processes and protocols  (Article 17 of Regulation (EU) 2018/389 – RTS on strong customer authentication and secure communication) and Transaction risk analysis (Article 18 of the Delegated Regulation)?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/389 - RTS on strong customer authentication and secure communication
  • ID: 2018_4170
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 17/12/2021

Fall back exemption

Article 33, § 6 of the RTS for strong customer authentication and common and secure open standards of communication (the “RTS”) provides that “Competent authorities, after consulting EBA to ensure a consistent application of the following conditions, shall exempt the account servicing payment service providers that have opted for a dedicated interface from the obligation to set up the contingency mechanism […]” (the “fall back exemption”). a) Which authority - the home authority or the host authority ?- is the compentent authority under article 33, § 6 of the RTS, when the “fall back exemption request” concerns the dedicated interface used in a Member state where a branch of the ASPSP is located? b) Does the answer differ if the same dedicated interface is used in the home member state and in the host member state where a branch is located?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/389 - RTS on strong customer authentication and secure communication
  • ID: 2018_4163
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 12/04/2019

Responsibility of national authority with regards to audit reports

Should all audit reports required under Article 3 of the RTS on strong customer authentication and secure communication be monitored by the competent national authorities?And, what are the consequences if the audit report addressing the audit (referred to in Article 3, paragraph 1 of the RTS) shows significant findings?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/389 - RTS on strong customer authentication and secure communication
  • ID: 2018_4155
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 26/10/2018

Review of Security Measures - Auditors expertise

Are internal auditors able to perform the audits as mentioned in paragraphs 1 and 2 of the RTS on strong customer authentication and secure communication?Is there a difference in the answer of this question between the audit as referred to in paragraph 1 and 2 of Article 3 of this RTS?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/389 - RTS on strong customer authentication and secure communication
  • ID: 2018_4153
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 26/10/2018

Review of the security measures: Audit report

Should the Audit for the implementation of the security measures be incorporated into an existing ISAE3402 report or COS3000 report or should a separate report be used?If a separate report should be used: Are there any templates available for reporting?Also, how detailed should the report be? Finally, should both design and operating effectiveness be tested of the requirements stated in the RTS articles?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/389 - RTS on strong customer authentication and secure communication
  • ID: 2018_4152
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 26/10/2018

Credit value date for payment transactions with currency conversion

As a credit entry on an account is possible only in the currency the account is maintained, does this mean that for a payment transaction the credit value date for the payee's account is no later than the business day on which the amount in the payee's account currency is credited to the payee's payment service provider's account?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_4150
  • Topic: Other topics
  • Date of submission:
  • Published as final Q&A: 12/03/2021

Major incidents reporting

Must Payment Service Providers (PSPs) submit major incident reports to their home National Competent Authority (NCA) when the cause of the major incident is outside the control of the PSP and when updates on the major incident are dependent on information provided by a third party?Where there is consolidated reporting of an incident to the EBA/ECB in the context of, for example, card payments schemes, is reporting of the major incident by PSPs to their NCA under PSD2 required?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2021/03 - Guidelines on major incident reporting under PSD2 - repealing EBA/GL/2017/10
  • ID: 2018_4144
  • Topic: Major incidents reporting
  • Date of submission:
  • Published as final Q&A: 14/12/2018

Authentication code

Is it allowed to use the (authenticated) session that a user has (after logging in (with or without SCA)) as 1 of the authentication factor when performing SCA for a payment transaction?For example: A customer logs in with its username & password (knowledge) + SMS One Time Password (possession). Once in his online banking environment he looks at his statements. Within that same session (that ends after 5 minutes inactivity) he makes a payment.The question is if for authenticating the payment it is required to perform SCA again or if the authenticated session (based on the previous authentication) and a second SMS One Time Password (possession) that dynamically links the payment would suffice.

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/389 - RTS on strong customer authentication and secure communication
  • ID: 2018_4141
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 24/05/2019

ASPSP is denied the waiver to the fall-back by an NCA

If an Account Servicing Payment Service Provider (ASPSP) is denied the waiver to the fall-back by a National Competent Authority (NCA) (i.e. at 13 September 2019), will the ASPSP still have 2 months to build the fall-back?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/389 - RTS on strong customer authentication and secure communication
  • ID: 2018_4140
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 22/03/2019

Testing eIDAS certificates before 14 September 2019

How can Third Party Providers (TPPs) and Account servicing payment service providers (ASPSPs) test their interfaces using PSD2 eIDAS-certificates during the testing period prior to September 2019 as it is only mandatory to use PSD2 eIDAS certificates from September 2019 onwards?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/389 - RTS on strong customer authentication and secure communication
  • ID: 2018_4138
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 07/06/2019

SMS OTP and credit card as a two authentication factor

Can we consider Credit card and One Time Password (OTP) SMS as a two authentication factor ? 

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/389 - RTS on strong customer authentication and secure communication
  • ID: 2018_4135
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 15/01/2021

Applicability of SCA to wallet solutions

Is a single Strong Customer Authentication (SCA) sufficient for transactions performed in staged wallet solutions? Does the funding transaction qualify as a transaction initiated by the payee only, which does not require SCA by the Account Servicing Payment Service Providers (ASPSP)?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_4133
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 21/05/2021

Payee-initiated transactions with irregular period or variable amount

Please clarify whether standing agreements between a customer and a merchant resulting in subsequent billing (irregular or otherwise) to be payee-initiated transactions, and as such excluded from the SCA requirement.

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_4131
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 01/03/2019

Trusted Beneficiary exemption – Management of the exemption, information flows between PSPs in the payment transaction

For the seamless management of the Article 13 exemption, should ASPSPs provide a feature that: 1) informs Acquirers and PISPs whether the payee is included in the payer’s list of trusted beneficiary; and 2) allows Acquirers and PISPs to suggest new entries or amendments to a payer’s list of trusted beneficiaries?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/389 - RTS on strong customer authentication and secure communication
  • ID: 2018_4128
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 25/01/2019

Application of Transaction Risk Analysis (TRA) exemption – Real time risk analysis / monitoring

Is it acceptable if a payment service provider (PSP) looking to apply the TRA exemption makes a best effort using the information available to them to identify that none of the six individual factors mentioned in Article 18(2)(c) of the Commission Delegated Regulation 2018/389 are applicable, but does not have to actually identify non-applicability of all of these factors to be able to use the TRA exemption? 

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/389 - RTS on strong customer authentication and secure communication
  • ID: 2018_4127
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 07/06/2019

Explicit consent required by the ASPSP from the PSU to enable the PSU to use the services provided by TPPs / Consenso esplicito richiesto dall’ASPSP al PSU per consentirgli di avvalersi dei servizi prestati dai TPP

May the requirement by the ASPSP for the PSU to give additional explicit consent in order to be allowed to use the services provided by TPPs, in addition to the consent given by the PSU to the TPP, be considered an ‘obstacle to the provision of payment initiation services and of account information services’ pursuant to Article 32 of the RTS?***IT:Puo’ un ulteriore consenso esplicito richiesto dall’ASPSP al PSU per consentirgli di avvalersi dei servizi prestati dai TPP, in aggiunta al consenso prestato dal PSU al TPP, essere considerato un “ostacolo alla prestazione dei servizi di disposizione di ordine di pagamento e di informazione sui conti” ai sensi dell’Articolo 32 del RTS?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/389 - RTS on strong customer authentication and secure communication
  • ID: 2018_4123
  • Topic: Other topics
  • Date of submission:
  • Published as final Q&A: 11/01/2019

Exemptions from Strong Customer Authentication (SCA): trusted beneficiaries

Should a Payment Service User (PSU) recreate a list of trusted beneficiaries that was already approved in accordance with the EBA Guidelines on the security of internet payments?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/389 - RTS on strong customer authentication and secure communication
  • ID: 2018_4120
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 21/12/2018

Sanctions list screening in the context of TPPs' services - risk management policy

Is the Account Servicing Payment Service Provider (ASPSP) obliged to recognise if a Third Party Payment Service Providers (TPP) is named on a sanctions list or even take some actions when the TPP becomes a designated entity? How the prohibition of directly or indirectly making funds or economic resources available to designated persons and entities is defined in this context?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_4117
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 12/03/2021

Data authentication standards

Does a non-remote card payment transaction with a secure, dynamic data authentication of the card (DDA or higher), based on ISO/IEC 7816 (for contact cards) and ISO/IEC 14443 (for contactless card) used with a static PIN meet the requirements of Article 4 of the RTS on Strong Customer Authentication (SCA)?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/389 - RTS on strong customer authentication and secure communication
  • ID: 2018_4110
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 20/12/2019

Scope of ‘initiation of an electronic payment transaction’

Does a card payment transaction, authenticated with a signature at the point of sale, fall under the scope of Article 97 (I) (b) PSD2? Is there a difference if the signature is provided on a paper or on a signature pad (e.g. electronic signature pad or signature capture at a payment terminal)?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/389 - RTS on strong customer authentication and secure communication
  • ID: 2018_4108
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 20/12/2019