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Exemptions from Strong Customer Authentication (SCA): credit transfers

Can the exemption under Article 15 of the RTS on SCA be applied to credit transfers between a personal account and a business account held by the same person.

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_4564| Topic: Strong customer authentication and common and secure communication (incl. access)| Date of submission: 21/02/2019

Unattended terminals and Transaction Risk Analysis (TRA) exemption and related Payment Service Providers (PSP)’s liabilities rules

Provided that both the payer’s Payment Service Provider (PSP) and the payee’s PSP can apply the strong customer authentication (SCA) exemption, without prejudice to the last say of the payer’s PSP, can a payment made at highway toll booths be treated as the one performed at the unattended terminals for transport fares?

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_4480| Topic: Strong customer authentication and common and secure communication (incl. access)| Date of submission: 23/01/2019

Dynamic linking: transactions for which the final amount is unknown and may be lower or higher than authenticated amount

For remote card transactions, is it acceptable that there are legitimate cases where the final amount may be lower or higher than the amount authenticated by the cardholder?

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: 2020_5133| Topic: Strong customer authentication and common and secure communication (incl. access)| Date of submission: 17/02/2020

Definition of payee for dynamic linking

Article 5 of the RTS on strong customer authentication and secure communication requires the authentication code to be specific to the amount of the payment transaction and the payee.Does it suffice to include a meaningful part of the identifier into the calculation of the authentication code? For instance, would it suffice to include only numeric characters of the IBAN in the calculation of the authentication code?

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_4556| Topic: Strong customer authentication and common and secure communication (incl. access)| Date of submission: 15/02/2019

Dynamic Linking for batch payments

With regards to dynamic linking for a batch of remote electronic payments, should the authentication code be linked to each and every IBAN of all the beneficiaries in a batch file?

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_4435| Topic: Strong customer authentication and common and secure communication (incl. access)| Date of submission: 27/12/2018

Dynamic linking for batch transactions

In relation to payment transactions for a batch of remote electronic payments to one or several payees, please clarify whether the payer needs to be made aware of every payee in the batch?

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_4415| Topic: Strong customer authentication and common and secure communication (incl. access)| Date of submission: 11/12/2018

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: 13/07/2018

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: 13/07/2018

Confidentiality of the application cryptogram for EMV transactions

Are EMV (Europay, MasterCard, Visa)  transactions (for which the application cryptogram is not enciphered during its transmission) compliant with the RTS on strong customer 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: 2018_4054| Topic: Strong customer authentication and common and secure communication (incl. access)| Date of submission: 28/06/2018

Contactless payments at point of sale - Applications of the conditions

With respect to Article 11 Paragraph b) of the RTS can we setup control for either 150 € or 5 transactions?

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_4225| Topic: Strong customer authentication and common and secure communication (incl. access)| Date of submission: 05/09/2018

Application of the low-value contactless exemption – Calculation of limits at Primary Account Number (PAN) / account level or at device / token level

May the counters for the application of the low-value contactless exemption be calculated at device/token level?

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_4036| Topic: Strong customer authentication and common and secure communication (incl. access)| Date of submission: 28/06/2018

Criteria for the application of the transaction risk analysis (TRA) exemption – Relevant fraud rates

Is only the Payment Service Provider (PSP) applying the TRA exemption required to have a fraud level below the reference fraud rate?

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_4034| Topic: Strong customer authentication and common and secure communication (incl. access)| Date of submission: 28/06/2018

Geographical scope of application of the RTS on strong customer authentication (SCA) and secure communication requirements – ‘Two-leg’ transactions

Is it necessary that issuer, acquirer, cardholder and merchant be all located in the EEA for the RTS on SCA requirements to apply to two-leg transactions?May the issuer use the merchant’s location as a proxy (in lieu of the acquirer’s location)?

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_4030| Topic: Strong customer authentication and common and secure communication (incl. access)| Date of submission: 28/06/2018

SCA at vending machines without PIN pad

Do transactions at vending machines without PIN pad require 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_4057| Topic: Strong customer authentication and common and secure communication (incl. access)| Date of submission: 28/06/2018

Review of security measures

When an issuer delegates strong customer authentication (SCA) to a third-party (e.g. a smartphone manufacturer), what are the requirements for such delegation? Should the issuer conduct an evaluation of the technical features and security of third-party’s devices and solutions?

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_4047| Topic: Strong customer authentication and common and secure communication (incl. access)| Date of submission: 28/06/2018

Confidentiality of offline PIN

Should the PIN transmitted offline from a terminal to an Europay, MasterCard and Visa (EMV) card always be enciphered? 

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_4055| Topic: Strong customer authentication and common and secure communication (incl. access)| Date of submission: 28/06/2018

Currency conversion of the EUR thresholds contained in the RTS

May payment service providers (PSPs) and card schemes set rounded and easily understandable non-EUR currency equivalents for the EUR thresholds set out in the 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_4040| Topic: Strong customer authentication and common and secure communication (incl. access)| Date of submission: 28/06/2018

Exemption for secure corporate payment processes and protocols

May lodged and virtual cards benefit from the exemption for secure corporate payment processes and protocols under Article 17 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_4060| Topic: Strong customer authentication and common and secure communication (incl. access)| Date of submission: 28/06/2018

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: 18/07/2018

Application of the Low Value Transaction Limits

Should the limits according the Article 16 RTS be applied to the account itself (account holder and authorized persons together) or should they be applied to the account holder (owner) and each authorized person (i.e. proxy of account holder) separately? Subsequently should the limits be applied to all remote payment transactions together or should e.g. card transactions and credit transfers be counted separately. Also should the limit be applied to all cards belonging to one person together or should the limit be applied to each card separately?

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_4429| Topic: Strong customer authentication and common and secure communication (incl. access)| Date of submission: 20/12/2018