SK&S advised the Polish Bank Association (ZBP) on the development of a joint position and recommendations of the banking sector with regard to implementation of the PSD2 directive

17.05.2019

SK&S advised the Polish Bank Association (ZBP) on the development of joint position and recommendations of the banking sector with regard to implementation of the PSD2 directive. The merit-related legal support, under the supervision of Marcin Olechowski, was provided by Wojciech Iwański and Mateusz Blocher who specialize in financial market regulations, including first and foremost payment services.

Work lasted over six months. Meetings of the working Team were attended by representatives of the legal, business and IT security departments of the majority of commercial banks operating on the Polish market.

The development of a joint position of the banking sector is a great success of the entire undertaking.

As pointed out by the Polish Bank Association, the Team’s goal was to interpret all these provisions that raised operational and practical doubts from the banks’ perspective, as well as that of introducing uniform standards in the procedure of banks in relations with consumers in the areas covered by the provisions of PSD2. In this way, efforts were made to improve the quality of customer service in the Polish banking sector.

Topics discussed included:

  • Strong Customer Authentication (SCA), including application of the Device Fingerprinting (DFP) method,
  • Unauthorized payment transactions,
  • Application Programming Interface (API)
  • exemption from the so-called fall-back option