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Applying for an exemption from maintaining a contingency mechanism for a PSD2 dedicated interface


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The reformed Payment Services Directive (PSD2) and the Commission Regulation (EU) 2018/3891 issued thereunder oblige banks and other account servicing payment service providers to enable their customers the right to use account information services, payment initiation services and new types of card-based payment instruments as of 14 September 2019.

In order that payment service providers could offer these new payment services to their customers, the bank or other account servicing payment service provider must provide a dedicated interface for this purpose or allow access to payment accounts through customer facing interfaces. The Commission Regulation provides both requirements concerning the dedicated interface and additional requirements for the use of customer facing interfaces.

The provision of a dedicated interface comes with an obligation to build a contingency mechanism (fall back) in the event of problems in the availability of the dedicated interface or its inadequate performance. However, account servicing payment service providers have the option to apply for an exemption from the requirement to implement the fall back if they can show that they meet the requirements for a dedicated interface defined in the Commission Regulation and covered in more detail in the Guidelines published on 4 December 2018 by the European Banking Authority (EBA)2. The contents of the application must comply with the EBA Guidelines. Where an account servicing payment service provider implements several PSD2 dedicated interfaces, it must, as a rule, apply for a separate exemption for each interface.

Subsidiaries of account servicing payment service providers must apply for an exemption with the competent authority of the country of location of the subsidiary. Branches must apply for an exemption with the competent authority in the country where company’s head office is located.

We request that you submit any applications for an exemption by 3 June 2019 to the registry office of the Financial Supervisory Authority (kirjaamo(at) in a format allowing the processing of the text. The application may be supplemented after the deadline if necessary. The application must indicate the journal number of the case (FIVA 1/02.07.03/2019) and specify which information contained therein is subject to business or professional secrecy. Where an account servicing payment service provider does not intend to apply for an exemption, we request that it communicates this to the FIN-FSA in a free-format notice by the date specified above.

Further information

  • Heli Mäkitalo, Risk Expert, tel. +358 9 183 5369, heli.makitalo(at)
  • Pasi Korhonen, Senior Risk Expert, tel. +358 9 183 5514, pasi.korhonen(at)

1COMMISSION DELEGATED REGULATION (EU) 2018/389 of 27 November 2017 supplementing Directive (EU) 2015/2366 of the European Parliament and of the Council with regard to regulatory technical standards for strong customer authentication and common and secure open standards of communication
2Guidelines of the European Banking Authority on the conditions to benefit from an exemption from the contingency mechanism under Article 33(6) of Regulation (EU) 2018/389 (regulatory technical standard on strong customer authentication and common and secure open standards of communication) (EBA/GL/2018/07)

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Regulator Information

Abbreviation: FIN-FSA
Jurisdiction: Finland

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