EBA欧洲银行-Issues-IV-VII-as-raised-by-EBA-WG-API_18页_548kb

EBA Responses to Issues IV to VII on APIs under PSD2

Core Content Overview

The document outlines the European Banking Authority's (EBA) responses to Issues IV to VII raised by participants in the EBA Working Group on APIs under the Second Payment Services Directive (PSD2). These responses focus on API performance and support, testing by TPPs, TPPs not authorised, and timelines for the fall-back exemption process. The EBA provides guidance and interpretations of the legal requirements, emphasizing the responsibility of the industry to implement the regulations effectively.

Issue IV: API Performance and Support

Description

Participants expressed concerns about the requirement in Article 32 of the RTS on SCA & CSC that ASPSPs (Account Servicing Payment Service Providers) must ensure their dedicated API interfaces offer the same level of availability, performance, and support as their PSU (Payment Service User) face-to-face interfaces.

Main Points

• The EBA states that absolute benchmarks cannot be defined for API performance because the level of service provided to PSUs varies between ASPSPs.
• The dedicated interface must match the performance and support levels of the best PSU interface(s) offered by the ASPSP.
• Key Performance Indicators (KPIs) and service level targets must be at least as stringent for APIs as for PSU interfaces.
• ASPSPs must publish data on the availability and performance of both their dedicated and PSU interfaces.

Issue V: List of TPPs Interested in Testing

Description

Participants raised concerns about the lack of a central list of TPPs (Third Party Providers) interested in testing APIs, making it hard for ASPSPs to identify suitable testing partners.

Main Points

• Article 30(5) of the RTS requires ASPSPs to provide testing facilities for TPPs to test their software and applications.
• The EBA does not advocate for a central list but encourages industry-led initiatives to facilitate communication between ASPSPs and TPPs.
• There are nine initiatives in the EBA Working Group that support this process.
• The EBA welcomes the publication of information on testing facilities and TPP availability by industry associations.

Issue VI: Testing by Non-Authorised Entities

Description

Participants questioned whether ASPSPs should allow non-authorised TPPs to test their APIs and whether they should offer the same level of service to these entities.

Main Points

• This issue requires legal interpretation of PSD2 and EBA guidelines.
• The EBA refers the response to its Q&A tool (Q&A 4609), published on 29 March 2019.
• The responsibility for ensuring compliance and testing lies with ASPSPs, and the EBA does not provide a direct stance on allowing non-authorised entities to test.

Issue VII: Timelines for the Fall-Back Exemption Process

Description

Participants requested greater transparency on the timelines for the fall-back exemption process across the 28 EU Member States.

Main Points

• The Annex provides indicative timelines for each country regarding the exemption process before 14 September 2019.
• These timelines are based on information provided by national competent authorities (NCAs) and are subject to change.
• The EBA does not provide binding timelines, but instead recommends that NCAs communicate the timelines through workshops, circular letters, and official websites.

Summary of Key Timelines

Key Takeaways

• The EBA does not set absolute performance standards for APIs, but requires them to match the best PSU interface standards.
• A central list of TPPs for testing is not proposed by the EBA; instead, industry-led initiatives are encouraged.
• The exemption from the fall-back mechanism is dependent on testing and compliance, with timelines varying by Member State.
• Testing facilities must be available by 14.03.2019 in most Member States.
• The EBA Q&A tool is the primary reference for legal interpretation of the exemption process.
• Communication of timelines is done via workshops, circular letters, and official websites.
• The exemption process must be completed by 14.09.2019, with no guarantees of timely processing.