ESBG - EACB Position Paper
Input to EBA on the Commission’s amendment of the draft final Regulatory Technical Standards on Strong Customer Authentication and Common and Secure Communication
The European savings, co-operative and retail banking community is calling on EBA to reject the amendment proposed by the Commission regarding a fall back to the dedicated interface for TPP access
1. Executive Summary
Via this Position Paper, ESBG and EACB are calling on EBA to reject the amendment proposed by the Commission regarding a fall back to the dedicated interface for TPP access. The European savings and retail banking community is arguing that the Commission’s promoted fall back to the dedicated interface for TPP access:
- Ignores the functioning of the online banking architecture, and hence will in most instances never be able to provide a “fall back” functionality;
- Proposes conditions for application (e.g. 30 seconds) in an environment (end-to-end communication over multiple channels with several parties involved) where actual responsibility for malfunction and/or failure is at best very tedious to allocate with certainty;
- Is totally askew with the many resilience and business continuity obligations already placed on and observed by ASPSP sector, under due supervision of their competent authorities;
- Does not assuage any concern with respect to customer protection, privacy, or security, and more generally will not allow ASPSPs to comply with their obligations under the GDPR (in addition, because of the resource burden involved, competent national authorities are very unlikely to effectively monitor TPPs’ compliance with the RTS as amended by the Commission);
- Is disproportionate in terms of resources, direct costs, and ancillary costs (including cost of capital) to the objective pursued, notably in the absence of any evidence that ASPSPs are not capable of providing a quality service with respect to the dedicated interface.
- In the case that EBA does not fully share the position of ESBG and EACB, the ESBG and EACB are suggesting a compromise proposal to avoid costs for ASPSPs - and in consequence for PSUs - for the maintenance of a fall back interface if not required.