Below is FDATA Europe’s response to the consultation on the SCA-RTS. We are grateful for the opportunity to respond, and would like to highlight a few points before presenting our formal response and recommendations:
• Article 10a exemption for TPPs needs to explicitly carve out the requirement to perform SCA every 90 days, and make it clear that ASPSPs do not have the option to require it after the initial connection is made and consent is in effect
• Any delays in the implementation of the proposed revisions to SCA-RTS will have materially negative impact on the entire UK market; 2023 is too long to wait, as a number of existing firms will necessarily leave the market due to customer attrition and churn, resulting in a spectacular failure of Open Banking. The timeline for change must be expedited.