Access to Accounts, fallback and obstacles
Obligation to offer dedicated interface, unless exemption
PSPs offering payment accounts accessible online will be obliged to offer dedicated interfaces for data exchange with Third-Party Payment Providers (TPPs), the option to offer direct access to the customer interface being removed. However the draft PSR introduces an exemption, allowing PSPs not to offer any dedicated interface if they have a specific business model in which payment services are of very little relevance. Criteria for granting this exemption are expected to be further described by the EBA.
Review of payment initiation services definition and what the PSPs need to expose in their dedicated interface
The Confirmation of Funds (CAF) payment service being very scarcely used, the CAF has been merged with the Payment Initiation Service (PIS). Also, the draft PSR specifies the minimum types of payment transactions that the dedicated interface should offer, as well as additional requirements ensuring that no obstacles remain.
No fallback, secured screen scraping
It is no longer mandatory to maintain a permanent fallback interface. However, in the event that dedicated interfaces are down and with authorization from the relevant National Competent Authorities (NCAs), TPPs should have the ability to securely utilize the customer interfaces by identifying themselves. This practice is also known in the market as ‘secured screen scraping’.
Drawing from the current EBA opinion on TPP service provision under PSD2, the draft PSR encompasses a non-exhaustive list of obstacles that dedicated interfaces should not create, ensuring unhindered provision of payment services.
Access to payment systems and payment accounts
The draft PSR reinforces the existing requirement to grant Payment Institutions (PIs) non-discriminatory access to payment systems and accounts held by credit institutions. The scope of the requirement has been expanded to encompass not only the onboarding but as well the offboarding of PIs and those in the process of obtaining a license.