The European Savings and Retail Banking Group (ESBG) welcomes the opportunity to respond to this public consultation from the European Banking Authority on the revision of the Guidelines on major incident reporting under PSD2.

ESBG and its Members are highly supportive of the proposed revision. We especially welcome the fact that the amended Guidelines optimise the reporting templates and allow PSPs more time to report major incidents to National Competent Authorities. We also appreciate that the new reporting framework will avoid the reporting of minor incidents, thus shifting banks’ time and resources on the really major ones. At the same time, ESBG and its Members would appreciate further clarity on the interpretation of some criteria and definitions and recommend the various reporting frameworks be further aligned. ESBG and its Members stand ready to further engage with the EBA in the weeks and months to come.

The EBA invites comments on all proposals put forward in this paper and in particular on the specific questions summarised in 5.2. Comments are most helpful if they:

  • respond to the question stated;
  • indicate the specific point to which a comment relates;
  • contain a clear rationale;
  • provide evidence to support the views expressed/ rationale proposed; and
  • describe any alternative regulatory choices the EBA should consider.