* The views expressed in this article are solely those of the authors and should not be attributed to the European Payments Council.
Created in January 2018, the Application Programming Interface Evaluation Group ( ) was composed of representatives from various account-servicing payment service providers (), third-party providers (), payment service users () as well as several regulators who participated as observers. The mission and mandate of the group were to provide market facing recommendations on the use of compliant to the revised Payment Services Directive () and to facilitate good market facing outcomes. By the end of 2018, the fulfilled its core mandate by publishing its recommended functionalities on the website. We interviewed the co-chairs James Whittle and Oscar Berglund to reflect on the groups’ work, challenges and evolution.
Could you elaborate on the creation and composition of the ?
The creation of this multi-stakeholder industry group was originally proposed by the European Commission (EC), as part of the final report of the Euro Retail Payments Board () Working Group on Payment Initiation Services () and welcomed by the as stipulated in its November 2017 meeting’s Statement. The composition was defined by the EC and consisted of:
- Three ASPSP representatives (European Banking Federation (EBF), European Savings and Retail Banking Group (ESBG) and European Association of Co-operative Banks (EACB));
- Three representatives (Bankin’, Klarna and PPRO);
- Three representatives (EuroCommerce, Ecommerce Europe and The European Consumer Organisation (BEUC));
- One representative from respectively the Electronic Money Association (EMA) and the European Payment Institutions Federation (EPIF).
The group was co-chaired by one representative from the ASPSP community (James Whittle, pay.uk) and one from the community (Oscar Berglund, Trustly).
The European Banking Authority (), the European Commission and European Central Bank (ECB) (until September 2018) supported the work of the as observers.
The agreed to provide secretariat support to the .
What was the main purpose of this group?
The objective of the was twofold. It was to help ensure that specifications, developed by five main initiatives (i.e. Berlin Group, Open Banking UK, Polish Initiative, Slovak Banking Initiative and STET), were compliant with the requirements of and the final Regulatory Technical Standards () on strong customer authentication () and common and secure open standards of communication () and other relevant legislation. And as importantly, that the specs would function well for the market of that will need to rely on them. By making recommendations it was the intention to achieve harmonisation of the specs that the initiatives were producing to promote consistency, interoperability and reduce unnecessary divergences between initiatives.
The was the first pan-European coordination group on , it has enabled the individual initiatives to more closely cooperate.
What were the main challenges the faced?
The central challenge was to bring together competitive parts of the European payments market to work together when their interests in relation to the legal framework of did not always align. For example, there still are strongly held views regarding the methods for strong customer authentication (). Nevertheless, the EG succeeded in issuing a guidance document in April 2018 with the blessing of the EG members.
As the worked, it also had to adjust to the fact that the legislators were still finalising their work. As it turned out this was actually more of a blessing than a challenge as it allowed the to help inform the practical understanding of legislators as they worked.
A key learning has been the benefit of bringing together practical industry guidance to work in harmony with the regulators.
Finally, it should also be noted that the only had decision-making power in relation to the guidance and recommendations that it was responsible for. Unfortunately, none of the Standardisation Initiatives have to date committed to implement all functionalities recommended by . We believe that the standardisation initiatives need to step up to the plate and implement the full range of functionalities to ensure that the specs they are producing are able to facilitate a full range of market choices to support good market-facing outcomes. The risk being that despite all energy and investment being made that payment services users, both users and merchants, would be left with worse services and lesser choice after compared to what existed prior. A lot is still at stake and we welcome the next phase of work being established by the .
Could you share the most significant achievements of the and briefly outline how they will help the market implement the relevant aspects of by September 2019?
Generally speaking, the provided a constructive platform via which the industry was able to identify key issues (e.g. in relation to , security and ) and define specific recommendations. Without a doubt the industry would have been worse off without the . We would like to thank the EC for promoting the creation of the group and the support and commitment shown by the and ECB.
On 9 November 2018 the published its recommended functionalities in pursuit of pan-European harmonisation and interoperability of standards (note: an updated version was published on 10 December 2018). This document describes the recommended functionalities for to achieve alignment to the , on & and the ’s Opinion and to ensure good market facing outcomes. We expect this to continue to be relevant to the market as guidance, but of course in the meantime the has, and will continue to, publish further relevant legal clarification under /, including some specifically aimed at clarifying uncertainty regarding the recommended functionalities.
Therefore, we encourage individual that are implementing to review the list of recommended functionalities, alongside the guidance and implement as many of them as possible in order to ensure a good market-facing outcome, including for their own customers.
Given that the wording of the on is intentionally vague we believe that the list of recommended functionalities provided unique market-facing guidance on what “good looks like” for . We hope that national competent authorities will find the recommendations informative as they assess to determine whether to grant an exemption from having to provide the contingency mechanism/”fallback” solution.
What are the next steps for the group if any?
The held its last in person meeting on 3 December 2018 having successfully fulfilled its core mandate. However, in anticipation of the creation of the working group on under in early 2019, the moved to a ‘ready to react’ mode in case any critical issues arose. The aim of the group will be to “identify issues that will emerge as the industry is preparing for the application date of the on & , and for external stakeholders to propose solutions on how these issues could be resolved, which national authorities and the can then consider”1.
Moreover, the ECB is expected to establish in due course a Working Group on a access scheme.
1European Banking Authority, https://eba.europa.eu/
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