Compliance with SCA in offline mode on an aircraft without internet connection

Article 97(1)(b) of  Directive 2015/2366/EU (PSD2) prescribes that the payment service provider (PSP) shall apply ‘strong customer authentication (SCA) where the payer initiates an electronic payment transaction’. Therefore, in the case where the payer initiates an electronic card-based payment transaction at a Point of Sale (POS) in offline mode or through a remote channel (the internet), the issuer shall apply Strong Customer Authentication (SCA) to that transaction, unless an exemption from  SCA  applies  in  accordance  with  Articles 11– 18 of the  Delegated  Regulation  (EU) 2018/389 . Other exemptions from SCA to those specified within the Delegated Regulation are not available. With regard to remote electronic transactions, Articles 4 and 5 of the Delegated Regulation also apply. In that regard, the specific case described above with a closed wireless network that does not have internet connectivity and does not use a POS terminal, may not allow SCA to be applied. In the case where the airplane is equipped with a POS terminal working in offline mode, the payer may be able to initiate an electronic card-based payment transaction and subsequently apply SCA. As clarified in Q&A 2018_4055 , the PIN can be transmitted and verified offline, provided that it meets the requirements of Articles 6(1), 22(1) and 22(4) of the Delegated Regulation.