Obstacles Faced by PISPs in Accessing Payment Status Information Under PSD2

Under Article 66(4)(b) of Directive (EU) 2015/2366 (PSD2), Account Servicing Payment Service Providers (ASPSPs) are required to provide Payment Initiation Service Providers (PISPs), “immediately after receipt of the payment order” from the PISP, with all information on the initiation of the payment transaction and all information accessible to the ASPSP regarding the execution of the payment transaction. This requirement is also set out in Article 36(1)(b) of Commission Delegated Regulation (EU) 2018/389 (the Delegated Regulation), which specifies that ASPSPs “shall, immediately after receipt of the payment order, provide [PISPs] with the same information on the initiation and execution of the payment transaction provided or made available to the payment service user when the transaction is initiated directly by the latter”. As clarified in Q&A 4601 , it follows from the above legal provisions that PISPs are entitled under Article 66(4)(b) PSD2 to the information on the execution status that is accessible to the ASPSP immediately after receipt of the payment order. PSD2 does not require ASPSPs to provide updates at a later stage. While ASPSPs may voluntarily provide such additional updates, they are not legally obliged to do so. Article 35(4)(b) of the Delegated Regulation, cited by the submitter, requires that PISPs include a unique reference to the payment transaction initiated. This provision relates to the secure identification and traceability of the transaction during the communication between ASPSPs and PISPs, and does not govern the conditions under which execution status information may be accessed after the transaction has been initiated. Accordingly, if an ASPSP chooses to provide additional execution status information to PISPs beyond what is required under PSD2, it may define the technical and security conditions for such access. This may include asking for an user token, provided such mechanisms do not obstruct access to the information that ASPSPs are legally required to provide under PSD2.