Introduction of additional mandatory steps or redirections in PISP payment initiation flows

In accordance with Article 32(3) of the RTS on SCA and CSC, may an ASPSP impose mandatory additional steps or redirections (pre-step) in a redirection-based payment initiation flow through a PISP, where such steps or redirections do not form part of the payment initiation process experienced by the PSU when using the ASPSP’s own mobile or online channels?

Article 32(3) of the RTS on SCA and CSC requires that the interfaces made available to PISPs do not create obstacles to the provision of payment initiation services. This requirement includes avoiding unnecessary additional steps or redirections that increase friction or reduce usability when compared with the PSU’s native experience. EBA Q&A 2021_6029, when interpreting Article 32(3) of the RTS on SCA and CSC, clarifies that additional registration requirements imposed by ASPSPs on TPPs that go beyond what is necessary to ensure secure access in accordance with the RTS constitute an obstacle within the meaning of that Article. This reflects the EBA’s view that interfaces should not impose unnecessary friction on PISPs and AISPs. In practice, however, some ASPSPs introduce additional pre-authentication steps in redirection-based payment initiation flows that are unnecessary and do not form part of the authentication experience that the PSU encounters in other online channels of the same ASPSP. In practice, these steps result in additional redirections or intermediate pages prior to the payment initiation request, increasing the complexity of the PISP payment process and leading to a less seamless experience compared with the PSU’s direct interaction with the ASPSP.