Article 32(2) of the Commission Delegated Regulation (EU) 2018/389 states that “account servicing payment service providers that have put in place a dedicated interface shall define transparent key performance indicators [KPIs] and service level targets, at least as stringent as those set for the interface used by their payment service users both in terms of availability and of data provided in accordance with Article 36”.

Guideline 2 of the EBA Guidelines on the conditions to benefit from an exemption from the contingency mechanism under Article 33(6) of the Delegated Regulation, defines a minimum set of KPIs for the dedicated interface. In particular, Guideline 2.3(a) defines “the daily average time (in milliseconds) taken, per request, for the account servicing payment service provider (ASPSP) to provide the payment initiation service provider (PISP) with all the information requested in accordance with Article 66(4)(b) of PSD2 and Article 36(1)(b) of the RTS”. The EBA also explained on page 43 of the EBA final report on these Guidelines that “the response time in GL 2.3 includes the interval between the point in time when a request is received by the ASPSP from a PISP […] and the point in time when all the information requested […] has been sent back by the ASPSP”. As highlighted by Article 32(2) of the Delegated Regulation, the KPIs defined by the ASPSPs should be as stringent as those for the customer interface. Therefore, whatever is included in the calculation of the response time for the payment service user (PSU) interface should also be included for the purpose of such calculation via-a-vis PISP. This may or may not include the time it takes the PSUs to authenticate themselves (the human intervention).

Given the interval measured is the one between the receipt of the request and sending the information back, where Strong Customer Authentication (SCA) is required, the time it takes for the ASPSP to perform SCA (including to verify the SCA information provided by the PSU) should be included, regardless of the method used for SCA, in a way that is “at least as stringent” as when calculating the response time where a PSU is using the PSU interface.