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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

Authentication code

Is an extra strong customer authentication (SCA) required, after logging in (with or without SCA) in the mobile application, to initiate the provisioning step to add the customers card to a third party wallet (e.g. Apple or Google pay)?

  • 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_4910
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 25/09/2020

SCA for contactless payments at a POS executed via a mobile device

1) Can we consider the strong customer authentication (SCA) outsourced from the issuer of cards to the payer? 2) Is it necessary for the issuer of the cards to perform SCA based on the elements of identification that are beyond its control?

  • 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_4937
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 25/09/2020

"Push based" authentication and SCA requirements

Does "push based" authentication fall in the Strong customer authentication (SCA) requirements, based on the security risks "push authentication" poses?

  • 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_4984
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 25/09/2020

Tokenised card details as a SCA possession element.

In relation to card tokenisation that can be used for the purposes of various payment solutions, does the token that is created from the card details qualify as a “possession element” according to 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_4827
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 07/08/2020

Insurance policy on minimum monetary amount of the professional indemnity insurance of PSD2

If an e-money payment institution (for the purpose of new PSD2 services - Payment Initiation Service Provider (PISP) and Account Information Service Provider (AISP) in line with insurance industry standards signed an insurance policy with insurance company for several thousand/million euros with franchise deductible (e.g. in the amount of 25k EUR), fulfills adequate capital requirements and is being regularly monitored by the regulator (local central bank), does the above mentioned insurance policy violate guidelines rule that the insurance policy should not have any excess, deductible or any threshold that could prejudice repayments or do we understand it correctly that such insurance policy does not in any case prejudice that potential refunds requests will not be refunded and it as such fulfills guideline requirements? We understand that such insurance does not prejudice any repayments.

  • 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_4542
  • Topic: Monetary amount of the professional indemnity insurance
  • Date of submission:
  • Published as final Q&A: 31/07/2020

Reporting of e-commerce card-based payment transactions falling within the scope of EBA Opinion EBA-Op-2019-06 for which no strong customer authentication was applied

Should e-commerce card-based payment transactions – falling within the scope of the EBA Opinion on the elements of strong customer authentication under PSD2 (EBA-Op-2019-06) and for which no strong customer authentication was applied – be reported under the higher-level category “Of which authenticated via non-strong customer authentication”?

  • 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: 2020_5070
  • Topic: Fraud reporting
  • Date of submission:
  • Published as final Q&A: 24/07/2020

Data breakdown on fraud by different card functions for cash withdrawals

Does the breakdown on “card payments by fraud types” in Table E of the EBA Guidelines on fraud reporting under PSD2 refer only to cards with a credit/delayed debit function?

  • 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_5056
  • Topic: Fraud reporting
  • Date of submission:
  • Published as final Q&A: 24/07/2020

Recording of card payments

If a card has both an e-money and non e-money function, how should a payment be recorded? Should the recording be different based on the type of the reporting institution (for example, depending on whether is an electronic money institution (EMI) or a bank)?

  • 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_5046
  • Topic: Fraud reporting
  • Date of submission:
  • Published as final Q&A: 24/07/2020

Recording of e-money

If a card issued by an E-money institution has a cash function, how should the cash withdrawal from that card be recorded? Should it be recorded on the debit card withdrawal, as the E-money breakdown section does not include a cash withdrawal category?

  • 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_5044
  • Topic: Fraud reporting
  • Date of submission:
  • Published as final Q&A: 24/07/2020

Direct debts fraud reporting

In relation to the direct debits fraud, please clarify the reporting criteria for direct debit fraud.

  • 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_5043
  • Topic: Fraud reporting
  • Date of submission:
  • Published as final Q&A: 24/07/2020

Reporting of PISP transactions

Should payment initiation service provider (PISP) initiated payments be reported under both Table A (1.1) and Table H (8.x)? More specifically how should these transactions be reported where the customer initiates a payment via a PISP, from their bank account, to one of their payees flagged in the bank’s online channel as “trusted beneficiaries” (Article 13 of the RTS on SCA&CSC).

  • 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_5042
  • Topic: Fraud reporting
  • Date of submission:
  • Published as final Q&A: 24/07/2020

Reporting of PISP initiated payments

Is there a requirement to segregate the Payment Initiation Service Provider (PISP) initiated payments which were executed without Strong customer authentication (SCA), by the relevant availed exemption used? Or are PISP initiated payments, only required to be presented in Bulk (Value, Volume, SCA/Non-SCA)?

  • 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_5041
  • Topic: Fraud reporting
  • Date of submission:
  • Published as final Q&A: 24/07/2020

Reporting of fraud by the acquirers

Regarding the fraud definition, could you please clarify how the following fraud examples should be classified by the acquirers

  • 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_5039
  • Topic: Fraud reporting
  • Date of submission:
  • Published as final Q&A: 24/07/2020

Reporting of card transactions that are out-of-scope from the requirement for SCA

In the Fraud Reporting, how should payment service providers (PSPs) report card transactions without Strong Customer Authentication (SCA) that are out of scope of the requirement for SCA, i.e. one-leg transactions and merchant-initiated transaction?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2019_4866
  • Topic: Fraud reporting
  • Date of submission:
  • Published as final Q&A: 24/07/2020

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

Strong Customer Authentication (SCA) possession element requirement for cryptographic validation

For a device to be considered possession:-a) should the device perform "cryptographically underpinned validity assertions using keys or cryptographic material stored in" the device?b) should the device be in the physical possession of the  Payment Service User (PSU)? I.e. it cannot be held and operated remotely.

  • 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_4532
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 24/07/2020

Electronic chip transactions authenticated with a hand signature

As a Payment Service Provider (PSP) acquirer, how should we report the German chip + signature transactions in the “EBA fraud report under PSD2” given the fact this kind of transactions are non-Strong Customer Authentication (SCA) and do not fall under any allowed exemption?

  • 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: 2018_4399
  • Topic: Fraud reporting
  • Date of submission:
  • Published as final Q&A: 24/07/2020

Separation of factors for strong customer authentication

If a mobile phone has two different e-banking apps on it, one for the banking agendas (a banking app where payments are initiated by entering password, possibly in combination with OTPs) and one for receiving the SMS OTPs (authorization app),would this scenario fulfill the PSD2 requirements of sufficient separation of both factors (since both factors reside on the same smartphone, but in different apps)?

  • 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_4637
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 19/06/2020

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:
  • Published as final Q&A: 19/06/2020