Legal requirement for ASPSPs to provide for cancellation of future dated pay-ments through its dedicated payment initiation services interface

Is there a legal requirement for ASPSPs to allow its PSU to cancel/revoke future dated payments via a payment initiation service provider, using the ASPSPs dedicated payment initiation services interface?

According to the PSD2, an ASPSP must provide it’s PSUs the same type of payment services through its own customer-oriented interfaces and its dedicated interfaces, PIS and AIS APIs. This understanding is further clarified in paragraph 29 of the Opinion on the implementation of the RTS on SCA&CSC ( EBA-Op-2018-04 ). However, there are no similar explicit requirements concerning revocation/cancellation of payments, neither in the PSD2 nor in the RTS. Q&A 2021_6318 states that “if an ASPSP offers its PSUs the possibility to initiate recurring transactions and future-dated payments, it should also allow PSUs to initiate such type of payments via a PISP”. Q&A 2021_6318 hence clearly states that a PSU must be able to initiate future dated/recurring payments via a PISP using the ASPSP’s PIS API. Furthermore, in  Q&A 2019_4496 , the European Commission states that: “In accordance with Article 80(4) of Directive (EU) 2015/2366 (PSD2), the PSU [...] can revoke its payment order to execute a future-dated payment transaction or a series of recurring future-dated payment transactions. This applies also to payment transactions initiated through a PISP [...] since Article 80(4) PSD2 is lex specialis to Article 80(2) PSD2. [...]”. Q&A2019_4496 hence states that a future-dated payment initiated through a PISP can be revoked through the customer facing interface of the ASPSP. In addition, Q&A 2019_4496 states, that “This instruction to revoke the order can be given by the PSU through the PISP or, directly, to the ASPSP”. This statement is however not referencing any legal foundation, nor does it impose a requirement, but only states that it can be done either way. In table 1 of the EBA Opinion on implementation of the RTS ( EBA-Op-2018-04 ), it is concluded that the dedicated interfaces offered by APSPS under PSD2 should allow “the possibility of cancelling an initiated transaction in accordance with PSD2, including recurring transactions” by referencing article 64(2), 80(2), and 80(4) of  PSD2 . However, none of these articles explicitly requires that a PSU shall be able to cancel a future dated payment through a PISP.