Clarification needed in dedicated Interfaces supervision

We seek clarification and insights into how competent authorities shall fulfill their responsibilities in line with Recital 23 and Article 32.2 of the Commission Delegated Regulation (EU) 2018/389, specifically regarding the supervision of payment initiation service's dedicated interfaces to ensure effective oversight and monitoring.

Given the guidelines of Regulation (EU) 2018/389: Recital 23:  "Where access to payment accounts is offered by means of a dedicated interface, in order to ensure the right of payment service users to make use of payment initiation service providers and of services enabling access to account information, as provided for in Directive (EU) 2015/2366, it is necessary to require that dedicated interfaces have the same level of availability and performance as the interface available to the payment service user. Account servicing payment service providers should also define transparent key performance indicators and service level targets for the availability and performance of dedicated interfaces that are at least as stringent as those for the interface used for their payment service users. Those interfaces should be tested by the payment service providers who will use them, and should be stress-tested and monitored by competent authorities." Article 32, Paragraph 2:  "Account servicing payment service providers that have put in place a dedicated interface shall define transparent key performance indicators and service level targets, at least as stringent as those set for the interface used by their payment service users both in terms of availability and of data provided in accordance with Article 36. Those interfaces, indicators, and targets shall be monitored by the competent authorities and stress-tested."   Instances have been noted where adherence to regulations could be improved.   For instance, PISPs have experienced numerous disruptions and ongoing issues with dedicated interfaces, including prolonged downtime and connectivity issues lasting several days or weeks. These disruptions have caused significant problems to PISP customers, such as eCommerce merchants who integrate the payment initiation service into their payment pages or checkouts, undermining confidence in payment initiation services among both merchants and PSUs. This, in turn, is hindering the adoption of the service and the successful implementation of PSD2.   Rather than NCAs supervising interfaces' performance and availability, NCAs frequently mandate PISPs to report issues directly to ASPSPs. This bypassing of the regulatory pathway places an additional burden on PISPs and may hinder the seamless resolution of interface issues and their performance.   Given that it is not the responsibility of Third-Party Providers to report every ASPSP interface downtime or issue to NCAs, it is necessary to clarify how competent authorities should conduct these tests and monitoring activities, including the methodologies and mechanisms they should use, and to provide the actual results of the monitoring and stress tests performed.