[Openid-specs-fapi] EBA Guidelines & Consent

Dave Tonge dave.tonge at momentumft.co.uk
Wed Dec 5 14:45:38 UTC 2018

Dear WG

As discussed on the call here is some of the latest guidance from the EBA
with regards to banks getting consent from users.

Its actually not as bad as I thought - banks are allowed to replay payment
details to end-users. However they are quite restricted on what they can
show users in regards to account information interactions.


The EBA agrees with the respondent stating that, in a
redirection scenario, the PSU’s interaction with the ASPSP
should be minimised to the extent that, as stated in the
new GL 5.1(b), the dedicated interface should ‘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’.
The EBA is of the view that asking the PSU to confirm if the
TPP can have access to the PSU account in general terms
before the ASPSP proceeds would likely be an obstacle,
given that such confirmation would amount to a check on

By contrast, the ASPSP may require the PSU to confirm the
payee and the amount of the payment transaction after
the PSU has input its credentials on the ASPSP’s domain
and before redirecting the PSU to the PISP’s interface,
without this representing an obstacle, in the same way as it
would do for its customers, and provided that, in line with
the amended GL 5.1(b), it does not use unclear or
unnecessary language and does not require the PSU to
provide or confirm superfluous information.

In an AIS context, with respect to the ASPSP displaying
information to the PSU following redirection from the AISP
on the type of access being requested, the duration, the
data and accounts, the EBA notes that it is the AISP’s
responsibility to obtain explicit consent for the data being
accessed. ASPSPs are not required to check or confirm the
terms of the consent provided by the PSU to AISPs or
PISPs. The presentation of this information should not be
used to obtain the PSU’s confirmation that they have
consented to the information being shared with the TPP

On the question of whether or not the selection of the
payment account on the ASPSP’s domain is an obstacle to
the provision of PIS services, the EBA is of the view that
this will depend on whether or not the PSU selects the
account at the level of the PISP, prior to being redirected to
the ASPSP for authentication. If the PSU selects the
account in the PISP’s domain, and the PISP communicates
the account selected to the ASPSP, together with the
payment initiation request, the EBA is of the view that the
ASPSP should not request that the PSU select the account
again before executing the PISP’s request. If the PSU does
not select the account in the PISP’s domain and the
account is not known in advance, the EBA is of the view
that the ASPSP may ask the customer to select the account
on the ASPSP’s domain, as part of the authentication step,
before the customer is redirected back to the PISP’s
interface, without this representing an obstacle.

Dave Tonge
[image: Moneyhub Enterprise]
Moneyhub Financial Technology, 5th Floor, 10 Temple Back, Bristol, BS1 6FL
t: +44 (0)117 280 5120

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