We are delighted to share EPIF's response to the EBA consultation on the Revised Guidelines on major incident reporting.

EPIF co-signed a joint industry letter that was sent to the EBA on the RTS on SCA and the use of CVV as a valid authentication factor. This letter was co-signed by: European Payment Institutions Federation (EPIF) Ecommerce Europe Eurocommerce European eCommerce and Omni-channel Trade Association (EMOTA) Merchant Risk Council (MRC0 Digital Europe

Please find below EPIF Q&A document that was submitted to the European Banking Authority asking for clarity on several PSD2 related issues. 

EPIF has highly appreciated the constructive dialogue with the European Commission and the EBA during this process but nonetheless has some final remakrs on the revised draft. EPIF is of the view that card-based transactiobs should be exempt from the dynamic linking requirement. EPIF suggesting relacinx the requirements to keep the maximum transaction amount to EUR 50 [...]

EPIF generally agrees with the proposed Guidelines 1-6 but underlines the importance of the Home State Principle and its application to the complaints procedure for alleged infringements of the PSD2.

EPIFsupports the PSD2’s creation of a central EBA Register, which will serve as a one-stop-shop for consumers and businesses alike to access up-to-date information about the Payment Service Providers (PSPs) they interact with. From a Payment Institution’s (PI) perspective, EPIF is of the view that the Register should provide capabilities for real-time partner verifications through fast [...]

EPIF would welcome confirmation as to whether agents who are not acting on behalf of a PI in providing payment services. The CCP should be able to manage country level reporting to the regulator but it is not necessary for the CCP to conduct its own additional offsite or onsite audits or investigations. EPIF would welcome [...]

EPIF is pleased to have co-signed a letter together with 18 other associations on the draft RTS on SCA. The letter provides the high-level postion of major payments industry operators with regards to the draft RTS on SCA. The letter ackknowledges the need for a Transaction Risk Analysis (TRS), supports a result-oriented approach and encourages [...]

EPIF is glad to share its response to the EBA consultation on the draft Guidelines on the information to be provided for the authorisation as payment institutions and emoney institutions and for the registration as account information service providers.

EPIF is pleased to share its response to the EBA Guidelines on major incident reporting under the PSD2. These draft Guidelines set out the criteria, thresholds and methodology to be used by payment service providers in order to determine whether an operational or security incident should be considered as major and, therefore, be notified to the [...]