EPIF is pleased to share its response to the EBA consultation on the Regulatory Technical Standards on strong customer authentication and secure communications under the PSD2. EPIF is supportive of initiatives that introduce more choice to innovation in the European payments sector and believes that we should adapt to customer needs and the rapid pace of change in the market. EPIF believes that Strong Authentication requirements should carefully balance security and user friendliness, taking into account payment service users’ desire for convenience. EPIF is strong supporter of the risk based approach. We believe the RTS should be less prescriptive and more business-model and technology neutral in order not to hamper innovation and the development of the EU Digital Single Market. Moreover, the RTS should be fully consistent with the provisions and spirit of the revised Payment Services Directive (PSD2) and its implied mandates given to the EBA.