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EBA opinion on obstacles related to PSD2 dedicated interfaces


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On 4 June 2020, the European Banking Authority (EBA) published an opinion on obstacles related to PSD2 dedicated interfaces, which are considered to hinder the provision of account information or payment initiation services. In accordance with Article 32(3) of Commission Delegated Regulation 2018/389, account servicing payment service providers (ASPSP) that have put in place a dedicated interface shall ensure that this interface does not create obstacles to the provision of payment initiation and account information services.

The Opinion presents views on methods considered to constitute an obstacle, as referred to in regulation, to the provision of new payment services and on the other hand examples of methods not considered obstacles within the meaning of regulation. The views presented in the Opinion are related to the following subject areas:

  • authentication procedures that ASPSPs’ interfaces are required to support;
  • payments at the point of sale and mandatory redirection;
  • multiple SCAs (strong customer authentication) in connection with initiating a payment or inquiring account data;
  • account information service and repeating the SCA every 90 days;
  • payment account selection;
  • additional checks on consent targeted at payment service users;
  • additional registration requirements concerning account information and payment initiation service providers.

The EBA will separately devise a supervision plan for national supervisory authorities to use in supervising that ASPSPs remove any obstacles identified in the PSD2 dedicated interfaces.  The EBA will monitor progress in the remedial actions in cooperation with the national supervisory authorities.  In its supervisory work, the FIN-FSA will adhere to the supervisory actions proposed by the EBA and will issue a separate supervision release on these actions and deadlines after the EBA’s supervision plan has been finalised.

For further information, please contact

  • Heli Mäkitalo, Risk Specialist, heli.makitalo(at)
  • Sanna Atrila, Senior Legal Adviser, sanna.atrila(at)
  • Hanna Heiskanen, Senior Digitalisation Specialist, hanna.heiskanen(at)


Background information

As from 14 September 2019, each account servicing payment service provider with payment accounts that are accessible online is obliged to offer at least one access interface enabling secure communication with account information service providers, payment initiation service providers and payment service providers issuing card-based payment instruments. The obligation is based on the Second Payment Services Directive (PSD2) and lower-level regulation issued thereunder. The opening of access to interfaces applies to banks and other payment service providers which provide customers with payment accounts used through an information network.

Banks and other ASPSPs have been allowed to decide whether to provide new payment service provider a dedicated interface with access to the payment account or to enable the use of the customer interface with additional elements required by regulation.  If access to payment accounts is provided through a separate interface, regulation requires that the dedicated interfaces represent the same availability and performance as the interface they provide to their customers.

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Regulator Information

Abbreviation: FIN-FSA
Jurisdiction: Finland

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