PSD2: 6 months count-down

We are less than 6 months away from Payment Services Directives 2 (PSD2) in effect in EU on Sept 14, 2019! As someone who has worked on this for almost a year, I will post some of my thoughts and challenges each month until the Sept date!

An f course, all thoughts expressed here belong to me and aren’t related to my employer.

Last week, in a semi-informal call with a friend at another company who is also working on PSD2, he reminded me that we are only 6 months away from PSD2 Strong Customer Authentication coming into effect. And how to copy with SCA, has now become the №1 priority for many e-commerce merchants. At the same time, there are still some unknowns,

Fresh update from EBA

The EBA on March 1st, 2019, updated its Single Rulebook Q&A and answered the most sought after question in terms out whether payee-initiated transactions, including credit card merchant-initiated transactions, are in or out-of-scope.

The first questions deals with ​Payee-initiated transactions with irregular period or variable amount (link)​:

whether standing agreements between a customer and a merchant resulting in subsequent billing (irregular or otherwise) to be payee-initiated transactions, and as such excluded from the SCA requirement.​

In which the EBA answered,

All transactions initiated pursuant to a standing agreement would not be subject to SCA, as these payments are initiated by the…