George Filippakis

A multidiscliplinary approach to Law, Finance and Technology

Mapping of Delegated Regulation 2018/389 on strong customer authentication

The Commission Delegated Regulation (EU) 2018/389, which is often referred to as the RTS on Strong Customer Authentication (SCA) and Common and Secure Communication (CSC), is one of the most practical and influential instruments under PSD II. For compliance and legal professionals, it provides the technical backbone of how secure digital payments and data sharing must work in the EU.

This Delegated Regulation goes beyond broad policy goals and sets out concrete, operational standards: how payment service providers (PSPs) authenticate users, how they protect data, and how they interact with third-party providers through open and secure channels. In short, it turns PSD II’s vision of open banking into everyday compliance reality.

Understanding the structure and intent of this Delegated Regulation is essential for anyone mapping obligations, interpreting supervisory expectations, or assessing how institutions can meet both security and innovation requirements under PSD II.

Below, you will find a mapping of the Delegated Regulation’s provisions. I have found this format to be very helpful in related gap analysis exercises, when assessing the compliance of a PSP with the corresponding provisions.

ArticleProvision summary
1. Subject MatterEstablishes that the Delegated Regulation lays down regulatory technical standards for strong customer authentication (SCA) and common and secure communication (CSC) under PSD II
2. General authentication requirementsPSPs must implement risk-based transaction monitoring to detect unauthorized or fraudulent activity, using factors such as compromised credentials, transaction amounts, known fraud patterns, malware indicators, and abnormal device or software usage.
3. Review of the security measuresRequires documentation, periodical testing, evaluation and auditing of the relevant security measures
4. Authentication codeWhen SCA is used (Article 97 para. 1 PSD II), the authentication shall be based on at least two elements categorised as knowledge, possession and inherence. Authentication by means of generating codes is subject to specific requirements
5. Dynamic linkingSecurity measures should be applied for the better validation of the transaction specifics (e.g., payment amount), while also ensuring confidentiality, authenticity and integrity
6. Requirements of the elements categorised as knowledgeRequires PSPs to adopt measures to mitigate the risk of knowledge elements being uncovered or disclosed to unauthorised parties
7. Requirements of the elements categorised as possessionSame as above, for possession elements
8. Requirements of devices and software linked to elements categorised as inherenceSame as above, for inherence elements
9. Independence of the elementsThe use SCA elements (knowledge, possession or inherence) should be subject to measures which ensure that the breach of one element does not compromise the reliability of the other elements
10. Payment account informationSubject to certain conditions, SCA may not be applied where a user is limited to accessing the balance of an account, or transactions executed in the last 90 days
11. Contactless payments at point of saleSubject to certain conditions, SCA may not be applied for contactless transactions of up to EUR 50
12. Unattended terminals for transport fares and parking feesSubject to certain conditions, SCA may not be applied at an unattended payment terminal for the purpose of paying a transport fare or a parking fee
13. Trusted beneficiariesSubject to certain conditions, SCA may not be applied when a payee is included in the list of trusted beneficiaries
14. Recurring transactionsSubject to certain conditions, SCA may not be applied for the initiation of a recurring transaction
15. Credit transfers between accounts held by the same natural or legal personSubject to certain conditions, SCA may not be applied for certain credit transfers
16. Low-value transactionsSubject to certain conditions, SCA may not be applied for electronic payment transactions of up to EUR 30
17. Secure corporate payment processes and protocolsSubject to certain conditions, SCA may not be applied in respect of legal persons
initiating electronic payment transactions through the use of dedicated payment processes or protocols that are only
made available to payers who are not consumers
18. Transaction risk analysisSubject to certain conditions, SCA may not be applied in cases where the electronic payment transaction has been assessed by the PSP as low risk
19. Calculation of fraud ratesPSPs shall ensure that overall fraud rates are equivalent to, or lower than, the reference fraud rate indicated in the Annex of the Delegated Regulation
20. Cessation of exemptions based on transaction risk analysisPSPs using Article 18 exemption (transaction risk analysis) must report to authorities if their fraud rates exceed reference levels, suspend Art. 18 exemption after two consecutive quarters of excess, and may only reinstate it (after notifying authorities) once fraud rates return to compliant levels
21. MonitoringTo make use of Articles 10 – 18 exemptions, PSPs must record and monitor certain payment transaction data
22. General requirementsGeneral requirements for confidentiality & integrity of the user’s personalised security credentials
23. Creation and transmission of credentialsPSPs must ensure that the creation of credentials is performed in a secured environment, and mitigate relevant risks
24. Association with the payment service userPSPs must ensure that only the use is associated with their personalised securit credentials
25. Delivery of credentials, authentication devices and softwareRequires PSPs to ensure that delivery of personalised security credentials etc. is carried out in a secure manner designed to address relevant risks
26. Renewal of personalised security credentialsRenewal or re-activation of personalised security credentials must adhere to the procedures for the creation, association and delivery of the credentials and of the authentication devices in accordance
with Articles 23, 24 and 25
27. Destruction, deactivation and revocationPSPs are required to have effective procedures in place for the destruction, deactivation and revocation of personalised security credentials
28. Requirements for identificationSecure identification must be ensured for the communication between the payer’s device and the payee’s acceptance devices for electronic payments
29. TraceabilityPSPs must ensure all payment transactions and interactions are fully traceable, using uniquely identified, securely logged, and time-synchronized communication sessions to enable complete post-event verification
30. General obligations for access interfacesAccount servicing PSPs offering online accounts must provide at least one secure, standardised interface that enables authorised third-party providers to identify themselves, access account data, and initiate payments using the bank’s authentication procedures; maintain confidentiality and integrity of credentials; follow recognised communication standards with transparent documentation and testing facilities; and ensure ongoing regulatory compliance under supervisory oversight
31. Access interface optionsAccount servicing PSPs must provide access for third-party providers either through a dedicated interface or by allowing them to use the same interfaces offered to their own payment service users for authentication and communication
32. Obligations for a dedicated interfaceAccount servicing PSPs using dedicated interfaces must ensure they perform as reliably as user-facing interfaces, define transparent performance indicators monitored by authorities, avoid creating obstacles for third-party providers (such as unnecessary redirections or extra authorisations), and publish quarterly statistics on the interfaces’ availability and performance
33. Contingency measures for a dedicated interfaceAccount servicing PSPs must have contingency plans for interface failures, notify affected third parties and authorities, and allow temporary use of customer-facing interfaces during outages; regulators may exempt providers from this requirement if their dedicated interfaces consistently meet reliability and performance standards
34. CertificatesPSPs must identify themselves using qualified electronic certificates under the eIDAS Regulation, which include their PSD II authorisation number, service role (e.g., account servicing, payment initiation, or information services), and competent authority details, ensuring secure and interoperable electronic identification across the EU
35. Security of communication sessionAll PSPs must use strong encryption to secure data exchanges, keep sessions short and properly linked, include clear references to users and transactions, and protect authentication credentials from disclosure, promptly notifying users if confidentiality is compromised
36. Data exchangesAccount servicing PSPs must securely share account and transaction data with authorized third parties, notify them of errors, and ensure access is limited to user-approved accounts, with usage frequency controlled

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