PayBelgium responds to EBA consultation on Draft Regulatory Technical Standards amending RTS SCA & CSC

PayBelgium and its members very much welcome the amendments to the RTS SCA & CSC that the EBA are suggesting in their consultation paper. While we would clearly prefer an approach where there is no need for the customer to renew their consent through SCA with the ASPSP, at least in use cases where the AISP retrieves the account information without the customer being present (instead requiring an initial SCA with the ASPSP + easy opt-out for the customer combined, at most, with a regular renewal of consent with the AISP), we understand that the EBA are of the firm view that such approach is incompatible with the PSD2 in its current form. We are therefore not requesting the EBA to reconsider this approach in the context of this consultation. Instead, we are merely sharing, by way of additional statement, why we believe it is justified for that approach to be considered in the context of the wider discussion on the review of the PSD2. As far as this particular consultation is concerned, we do have some suggestions for certain additional amendments that we believe the PSD2 allows and that would further improve the situation for AISPs and their customers. We explain our suggestions under Q2 and Q3 of our response.

Download the full response here

Published on 24/11/2021

PayBelgium agrees with the European Commission's suggestion that payment institutions and electronic money institutions should be eligible to get direct access to designated systems (e.g. Target2/TIPS), in line with the Retail Payments Strategy. Currently, non-banks must rely on banks to execute payment transactions, which adds costs to the customer and concentrates risk. Direct access to designated systems for non-bank payment institutions/electronic money institutions will contribute to creating a competitive Digital Single Market in financial services and a more resilient financial sector. It will also mitigate the impact of de-risking within the sector.

Download the full response here

Published on 06/05/2021

PayBelgium comments on the EDPB Guidelines on the interplay of the PSD2 and the GDPR

PayBelgium commented on the European Data Protection Board (EDPB) Guidelines 06/2020 on the interplay of the Second Payment Services Directive and the GDPR.

Download the full response here

Published on 15/09/2020