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ARTICLE · 27 JANUARY 2026

EBA Q&A Clarifies Strong Customer Authentication Requirements In Open Banking Solutions

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The evolving landscape of online payments under the Payment Services Directive (2015/2366) ("PSD2") has consistently aimed to provide consumers with efficient, convenient and secure payment methods...

MaltaFinance and Banking
James Debono
James Debono
Emma Attard Bondi
Emma Attard Bondi
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The evolving landscape of online payments under the Payment Services Directive (2015/2366) ("PSD2") has consistently aimed to provide consumers with efficient, convenient and secure payment methods. Central to this effort is the application of strong customer authentication ("SCA"), a security measure requiring two or more independent factors to verify a user's identity for online payments or account access. However, its practical implementation often faces friction.

Pertinent to the issue is the Commission Delegated Regulation (EU) 2018/389 ("Regulation"), supplementing PSD2 with regulatory technical standards on SCA. Article 32(3) of the Regulation explicitly prohibits account servicing payment service providers ("ASPSPs"), such as banks, from creating obstacles to the provision of open bank services, namely payment initiation ("PIS") and account information services ("AIS") by third parties in the interface provided to their clients (the payment service

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