Obstacle assessment of a mandatory client segment selection screen in a redirection journey

Article 32(3) of Commission Delegated Regulation (EU) 2018/389 requires account servicing payment service providers (ASPSPs) that have implemented a dedicated interface to ensure that the interface does not create obstacles to the provision of payment initiation and account information services. As clarified in paragraphs 6, 7 and 15 of the EBA Opinion on obstacles under Article 32(3)of the RTS on SCA and CSC (EBA/OP/2020/10) , in a redirection or decoupled approach the interaction between the payment service user (PSU) and the ASPSP should be minimised to what is necessary in order for the PSU to authenticate. The authentication procedure with the ASPSP as part of an AIS or PIS journey should not include unnecessary steps or require the PSU to provide unnecessary or superfluous information compared to the way in which the PSU can authenticate when directly accessing their payment accounts or initiating a payment with the ASPSP. In circumstances where, when PSUs access their accounts directly via the ASPSP’s customer interface, authentication is performed without requiring the PSU to manually select a client segment, such a step introduced in a redirection journey does not appear necessary for the purpose of authentication. As such a step does not appear necessary and results in additional friction in the AIS or PIS journey compared to the way in which the PSU can authenticate when directly accessing their payment accounts or initiating a payment with the ASPSP, this constitutes an obstacle within the meaning of Article 32(3) of the RTS.