+Guideline 5: Obstacles

Guideline 5: Obstacles

5.1 The ASPSP should provide the competent authority with:

a. a summary of the method(s) of carrying out the authentication procedure(s) of the PSUs that are supported by the dedicated interface, i.e. redirection, decoupled, embedded or a combination thereof; and
b. an explanation of the reasons why the method(s) of carrying out the authentication procedure(s) referred to in paragraph (a) is/are not an obstacle, as referred to in Article 32(3) of the RTS, and how such method(s) allow(s) PISPs and AISPs to rely on all the authentication procedures provided by the ASPSP to its PSUs, together with evidence that the dedicated interface does not give rise to unnecessary delay or friction in the experience available to the PSUs when accessing their account via a PISP, AISP or CBPII or to any other attributes, including unnecessary or superfluous steps or the use of unclear or discouraging language, that would directly or indirectly dissuade the PSUs from using the services of PISPs, AISPs and CBPIIs.

5.2 As part of the explanation referred to in letter (b) of Guideline 5.1, the ASPSP should provide the competent authority with a confirmation that:

a. the dedicated interface does not prevent PISPs and AISPs from relying upon the authentication procedure(s) provided by the ASPSP to its PSUs;
b. no additional authorisations or registrations are required from PISPs, AISPs or CBPIIs, other than those imposed in Articles 11, 14 and 15 of PSD2;
c. there are no additional checks by the ASPSP on the consent, as referred to in Article 32(3) of the RTS, given by the PSU to the PISP or the AISP to access the information on the payment account(s) held with the ASPSP or to initiate payments; and
d. no checks on the consent given by the PSU to the CBPII in accordance with letter (a) of Article 65(2) of PSD2 are performed.

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