Payment Initiation Service - Batch payment / bulk payment

As clarified in paragraph 29 of the Opinion on the implementation of the RTS on SCA&CSC (EBA-Op-2018-04), a payment initiation service provider (PISP) ‘has the right to initiate the same transactions that the ASPSP offers to its own PSUs, such as instant payments, batch payments, international payments, recurring transactions, payments set by national schemes and future-dated payments.’ Therefore, ASPSPs should offer to PSUs the possibility to initiate batch payment transactions through a PISP if they have the same possibility via the ASPSP’s direct customer interface.   Q&A 5184 further clarified that ‘should the PSU be required to add a new payee to a list of pre-registered beneficiaries before initiating a payment transaction directly with its account servicing payment service provider (ASPSP), the PSU should be able to add a new payee to a list of pre-registered beneficiaries in a payment initiation service (PIS) journey and to do so without any additional and unnecessary steps compared to when the PSU is adding the new payee directly with its account servicing payment service provider (ASPSP).’ The same principle applies to adding new payees in the list of pre-registered beneficiaries when the PSU initiates a batch payment.   In addition, also in line with Q&A 5184, adding new payees to the list of pre-registered beneficiaries in a PIS journey may require the application of an SCA in accordance with Article 97(1)(c) PSD2 if the application of an SCA is also required when the PSU is adding new payees directly with its ASPSP.