BT-REQ-3972 PSD3 Impacts v6(without crop marks) RL - Flipbook - Page 16
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HL | PSD3 Impacts
8. TPP access
(PSR Arts 35–39, 44–45)
Overview
Much of the RTS on SCA and secure
communications has been absorbed into the
proposed PSR.
ASPSPs will be required to implement
dedicated interface solutions for TPP access.
In the event that the dedicated interface is
unavailable, ASPSPs may have to offer an
alternative interface without delay, with TPPs
able to lobby regulators that they should have
use of the customer interface if this takes too
long. The Council Text, however, has removed
these last two elements.
What is changing?
The proposed PSR now requires all ASPSPs to rely
on a dedicated customer interface for TPP access.
The obligation to maintain a contingency
mechanism, or apply for an exemption from doing
so, has been “replaced” in the Original Commission
Draft with the requirement to offer an alternative
interface without delay in the event that a dedicated
interface becomes unavailable. TPPs can ask their
NCA to require the ASPSP to allow them to use the
customer interface if this takes too long. The Council
Text has removed both of these elements.
PSPs can apply to their NCA to use the customer
interface in place of a dedicated customer interface.
The EP Text proposes to require ASPSPs to always
allow access to interfaces that allow business
continuity for TPPs and, where an ASPSP permits
multiple SCA options, to allow the TPP the option to
choose what can be offered to the payer.
Interestingly all three texts permit ASPSPs to apply
for a derogation from having to have a dedicated
interface (relying instead on a customer interface)
or from having to ‘offer any interface at all for secure
data exchange’, with the EBA to provide RTS on the
granting of such an exemption.
The Council Text limits these standards to the
exemption from having to have an interface at all,
committing the EBA to consider ‘inter alia... the
size, annual turnover and payments volume of
the account servicing payment service provider’.
What is the impact?
ASPSPs with a modified customer interface will
either have to apply to their NCA to be allowed
to use their customer interface for TPP access,
or will need to move to a dedicated customer
interface.
ASPSPs that currently have the benefit of the
contingency mechanism exemption will now
need to ensure that they are able to make an
alternative interface available to TPPs “without
delay” (and potentially the customer interface if
requested).
Both could involve significant regulatory projects
requiring considerable tech build.
As before, this will not be subject to the corporate
optout so ASPSPs operating in the corporate
banking space will be required to undertake
regulatory projects requiring operational build for
TPPs that have shown limited interest (if any) in
accessing accounts in this space unless they can
be exempted from the requirement to provide an
interface at all.
