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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

Keyed Mail Order or Telephone Order (MO-TO) transactions

In the hotel industry, if a consumer contacts the hotel directly to make a reservation, the hotel may need to manually key the payment details into their payment terminals. Does this qualify as a Mail Order or Telephone Order (MO-TO) transaction?

  • 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: 2019_4790
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 12/03/2021

Treatment of electronic bookings similar to Mail Order and Telephone Orders (MO-TO) transactions

Would hotel use-cases, which include reservations taken by third parties (such as online travel agents or brand/hotel group) for the merchant and subsequent transactions (such as post-booking processing of prepaid rates or deposits, processing of cancellation/no-show fees, processing of post-checkout charges) fall under the scope of Mail Order and Telephone Orders (MO-TO) transactions and are they therefore excluded from the strong customer authentication (SCA) requirements?

  • 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: 2019_4788
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 12/03/2021

Unsuccessful authentications and declined transactions effect on the counters of cumulative amount and number of consecutive transactions

Do failed authentications or declined transactions increase the counters of cumulative amount or number of hits?

  • 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: 2019_4785
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 06/12/2019

Delayed or deferred PIN for wearable devices

Is the PIN entered when the cardholder takes on wearable device on, still valid as a knowledge element for one or several transactions later the same day, if it can be ensured that the device has not been taken off?

  • 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: 2019_4783
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 25/09/2020

More than one transaction from a single consumer initiated transaction

When a consumer elects to add an additional item to their purchase at the time of checkout (a cross sale) they are making two purchases from two different merchants in a single session. Is SCA required for both of these transactions? This would make the user experience very clumsy and awkward as the consumer would have to go through SCA twice in a row during a single checkout.

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2019_4776
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 21/01/2022

Requirement for credit institutions and electronic money institutions wishing to offer PIS and AIS to take out professional indemnity insurance or a comparable guarantee / Obbligo di dotarsi di un'assicurazione per la responsabilità civile o analoga garanzia, per gli Enti creditizi o Istituti di moneta elettronica che vogliono offrire i servizi di PIS e AIS

Can an electronic money institution or a credit institution wishing to offer Payment Initiation Service (PIS) and Account information service (AIS) consider its own funds to be a guarantee that is comparable to professional indemnity insurance (PII)?***IT:   Un Istituto di Moneta elettronica o un Ente creditizio che vuole offrire i servizi di PIS e AIS, può considerare i fondi propri come analoga garanzia rispetto all’assicurazione per la responsabilità civile professionale? 

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2017/08 - Guidelines on the criteria on how to stipulate the minimum monetary amount of the professional indemnity insurance
  • ID: 2019_4753
  • Topic: Monetary amount of the professional indemnity insurance
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Authorisation for the provision of PIS and AIS on behalf of other legal entities belonging to the same corporate group / Autorizzazione ad offrire servizi di PIS e AIS per conto di altre Legal Entity appartenenti allo stesso Gruppo societario

In a corporate group which is not listed in the register of banking groups and in which there is both an electronic money institution and a credit institution, can the electronic money institution offer payment initiation services (PIS) and account information services (AIS), including on behalf of the group’s credit institution that also provides the same service? Must the electronic money institution as a service provider offering PIS and AIS to clients of the group’s credit institution provide its own certificate, the group certificate, or the credit institution’s certificate to the other account servicing payment service providers (ASPSPs)? Or, as it is merely a service provider, is it the credit institution’s certificate that should be displayed? Can a corporate group request a group certificate to provide to the other ASPSPs and/or third party providers (TPPs)? *** IT:  In un Gruppo societario, che non è iscritto al registro dei Gruppi Bancari e al cui interno sono presenti sia un Istituto di moneta elettronica che un Ente creditizio, l’Istituto di moneta elettronica può offrire i servizi di PIS e AIS, anche per conto dell’Ente creditizio del Gruppo in qualità di fornitore del servizio stesso? L’Istituto di moneta elettronica che offre i servizi di PIS e AIS ai clienti dell’Ente creditizio di Gruppo, in qualità di fornitore del servizio, si deve presentare verso gli altri ASPSP con il proprio certificato, con il certificato di Gruppo oppure con il certificato dell’Ente creditizio? O in quanto mero fornitore del servizio, il certificato da esporre è quello dell’Ente creditizio? Un Gruppo societario può richiedere un certificato di Gruppo per presentarsi alle altre ASPSP e/o TPP?

  • 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: 2019_4752
  • Topic: Authorisation and registration
  • Date of submission:
  • Published as final Q&A: 25/09/2020

Compliance with SCA in offline mode on an aircraft without internet connection

How can Strong Customer Authentication (SCA) be applied in an offline environment onboard an airplane when chip and pin cannot be verified with a Point of Sale (POS) device? Specifically, how is dynamic linking achieved in an offline mode for airlines who don't have internet connectivity but instead have a closed wireless network to be able to make purchases onboard an aircraft?

  • 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: 2019_4740
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 06/12/2019

AISPs and scope of application AML requirements

1. To what extend do AISPs need to comply with the obligations in relation to anti-money laundering and terrorist financing under Directive (EU) 2015/849 of the European Parliament? 2. Is a requirement for AISPs on the basis of national law and national supervisory practices to submit to the competent supervisor a description of the internal control mechanisms with regard to AML regulations compliant with PSD2 and EBA’s Guidelines on Guidelines on authorisation and registration under PSD2?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2019_4712
  • Topic: Authorisation and registration
  • Date of submission:
  • Published as final Q&A: 11/03/2022

Report of fraud rates by issuers and acquirers

For card-based transactions: - When the issuer reports frauds under the EBA Guidelines on fraud reporting (EBA/GL/2018/05), shall the issuer provide information on the unauthorised transactions for which the acquirer has applied an exemption? If so, shall the issuer provide a break-down according to the different exemptions applied by the acquirer?- When the acquirer reports frauds under the EBA Guidelines on fraud reporting, shall the acquirer provide information on the unauthorised transactions for which the issuer has applied an exemption? If so, shall the acquirer provide a break-down according to the different exemptions applied by the issuer?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2018/05 - Guidelines on fraud reporting under PSD2 (amended by EBA/GL/2020/01)
  • ID: 2019_4703
  • Topic: Fraud reporting
  • Date of submission:
  • Published as final Q&A: 24/07/2020

Transaction risk analysis (TRA) exemption – Calculation of fraud rate – Impact of unauthorized transactions on issuers and acquirers

In the case of card-based transactions, shall issuers include in their fraud rate calculation only the unauthorized transactions for which they apply strong customer authentication (SCA) or an exemption?  Or, shall issuers also include unauthorised transactions for which the acquirer applies an exemption?Shall acquirers include in their fraud rate calculation only the unauthorised transactions for which they apply an exemption?  Or shall acquirers also include unauthorised transactions for which the issuer applies an 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: 2019_4702
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 24/07/2020

Scope of the corporate SCA exemption.

Does the corporate SCA exemption apply only if the payer initiates (and transmits) payments directly to their ASPSP and not for payments transmitted via a 3rd party service provider (i.e. a PISP)?

  • 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: 2019_4693
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 14/06/2019

What is considered as a dedicated interface

Payment Service Users (PSUs) communicate with an account servicing payment service provider (ASPSP) via Web using HTTP while mobile PSUs and Third Party Providers (TPPs) via REST Application Programming Interfaces (APIs) but in all cases the processing is done by the same back-end server using the same credentials, authorisations and business logic. In the case of mobile and TPP channels, the APIs are similar and are exposed from the same ASPSP’s gateway. Any issue in the back-end server will result in downtime for all channels. Clarification is required whether this solution is considered as a dedicated interface or not.

  • 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: 2019_4681
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 09/08/2019

"Authorisation number" in eIDAS certificates

There are two possible interpretations of the Regulation (EU) 2018/389 (RTS) Article 34 paragraph (2) in the case of payment service providers registered in Member State “A”:1) The authorisation number is the number of the resolution of the NCA (or its predecessor in title) authorising the provision of payment services for the specific PSP, which is not the same as the Registration number appearing in the NCA’s public register.2) The authorisation number is the Registration number appearing in the NCA’s public register (which is a reference number formed based on the VAT number).Please clarify whether interpretation 2) above is in line with the requirements of the RTS? Please clarify whether the 8-digit Registration number (based on the VAT number) appearing in the NCA’s public register, and appearing as “National Identification Number” in the EBA PSD2 register or as “National Reference” in the EBA credit institution register can be used as the “authorisation number” in eIDAS certificates?

  • 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: 2019_4679
  • Topic: Central register of the EBA
  • Date of submission:
  • Published as final Q&A: 14/06/2019

Compliance of (1) card data (2) SMS OTP and (3) EMV 3DS behaviour-based inherence as an authentication information with the requirements of PSD2 and RTS on SCA

Could the use of (1) card data (2) SMS One Time Password (OTP) and (3) Europay, MasterCard, Visa (EMV) 3-D secure (3DS) behaviour-based inherence information as an authentication solution be considered compliant with the PSD2 and RTS on strong customer authentication and secure communication requirements?

  • 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: 2019_4671
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 05/03/2021

Applicability of SCA to electronically processed SEPA Direct Debits / Interpretation of EBA Q&A 2018_4359

Are mandates for direct debits which are set up without direct involvement of the payer’s PSP subject to SCA requirements?

  • 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: 2019_4664
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 07/06/2019

Define what is “given period of time”

What constitutes a “given period of time” as expressed in Article 4.3 (b) of the RTS on strong customer authentication and secure communication?

  • 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: 2019_4662
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 19/06/2020

Inclusion of time taken for SCA in the performance KPI

Does the Key Performance Indicator (KPI) for the performance of the dedicated interface include the time taken for conducting 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: 2019_4661
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 09/08/2019

Relying on vendor mechanisms processing the biometric data for strong customer authentication; Multiple fingerprint samples stored on a mobile device and used for purpose of user authentication.

Are the obligations of a payment service provider (PSP) laid down in the Article 8 of RTS on strong customer authentication and secure communication fulfilled in case the biometric credentials of customer are stored at the device level and the strong customer authentication itself is processed by the mobile device? In this context, are the obligations of the PSP laid down in Article 8 and 24 of RTS on Strong Customer Authentication fulfilled in case the mobile device stores multiple fingerprint samples for user authentication?

  • 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: 2019_4651
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 25/09/2020