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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

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

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:
  • Published as final Q&A: 20/12/2019

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

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

Transaction Risk Analysis (TRA) exemption – Time period for calculation of initial fraud rate

What is the relevant time period to use when calculating the initial fraud rate for use when the Strong Customer Authentication (SCA) comes into force?

  • 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_4044
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 08/11/2019

3 month notification period on interface changes to ASPSPs’ interfaces

Do account servicing payment service providers (ASPSPs) need to adhere to a 3 month notification period for all interface changes, or only for breaking interface changes, as specified in the RTS on on strong customer authentication (SCA) and secure communication (CSC) Article 30 Paragraph 4?

  • 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_4823
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 11/10/2019

Applicability of exemption under RTS Article 16 for payee’s PSPs (acquirers)

Can an exemption under Article 16 of the RTS on strong customer authentication and secure communication be applied by the payee’s payment service provider (PSP) (the acquirer) for card-based 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_4242
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 11/10/2019

Applicability of exemption under RTS Article 11 for payee’s PSPs (acquirers)

Can an exemption under Article 11 of the RTS on strong customer authentication and secure communication be applied by the payee's payment service provider (PSP) (the acquirer) for card-based 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_4241
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 11/10/2019

Contactless counting

For the purpose of counting previous cumulative contactless transactions in order to assess the eligibility of the exemption in Article 11 of the RTS, should contactless transactions initiated outside of the EEA be included?

  • 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_4227
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 11/10/2019

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:
  • Published as final Q&A: 11/10/2019

Application of limits for Strong customer authentication (SCA) exemption

How should payment service providers (PSPs) apply the cumulative limits set in Articles 11 and 16 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: 2018_4182
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 11/10/2019

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:
  • Published as final Q&A: 11/10/2019

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:
  • Published as final Q&A: 11/10/2019

Clarification on whether a particular business model type constitutes the provision of an account information service as defined by Article 4 (16) of PSD2

Does a business model where the provider offers a service sending the account information to third parties (different from the payment service user)  (detail provided in the background) constitute the provision of an account information service, particularly as it is not proposed that the account information obtained will be given directly to the Payment Service User?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_4098
  • Topic: Authorisation and registration
  • Date of submission:
  • Published as final Q&A: 13/09/2019

Is the scope of the RTS on strong customer authentication (SCA) and secure communication one-leg or two-leg?

Does the PSD2 requirement on SCA, and subsequently the detailed requirements in the RTS on SCA including the practical usage of the allowed exemptions, apply also to one-leg transactions, with regards to:Transactions with the payer’s payment service providers (PSP) outside the EEA (credit transfers as well as card-based payments)?Credit transfers with the payer’s PSP inside the EEA and the payee’s PSP outside the EEA?Card-based payments with the payer’s PSP (the issuer) inside the EEA and the payee’s PSP (the acquirer) outside the EEA, when the non-EEA acquirer do support SCA?Card-based payments with the payer’s PSP (the issuer) inside the EEA and the payee’s PSP (the acquirer) outside the EEA, when the non-EEA acquirer does not support 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_4233
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 06/09/2019

The Implementation of the electronic communications exclusion in the voiced-based premium rate services market

Considering the organisation of the voiced-based premium rate services market, and considering the interpretations proposed for the electronic communications exclusion (ECE) in the different countries, as far as a payment transaction complies with the conditions imposed by the ECE, does the ECE apply to the whole value chain, and therefore, all the providers of electronic communications networks or services involved in payment transactions covered by the ECE should not have to register as payment institutions or agents for these operations?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_4181
  • Topic: Other topics
  • Date of submission:
  • Published as final Q&A: 06/09/2019

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:
  • Published as final Q&A: 06/09/2019

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

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

Contactless transactions - SCA

Does the cumulative count / authorised sum amount apply to any contactless authorisation request, regardless if the request was approved 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: 2018_4230
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 09/08/2019