PSD2 Is In Trouble: Will It Survive?

This blog post has been coauthored with Karen Lewison

The 2nd Payment Services Directive (PSD2) of the European Union went into effect on September 14, but one of its most prominent provisions, the Strong Customer Authentication (SCA) requirement, was postponed until December 31, 2020 by an opinion dated 16 October 2019 of the European Banking Authority (EBA). The EBA cited pushback from the National Competent Authorities (NCAs) of the EU member countries as the reason for the postponement, and the fact that version 2 of the 3-D Secure protocol (3-D Secure 2) is not ready as a reason for the pushback.

PSD2 is supposed to be technology neutral, but the EBA has unequivocally endorsed 3-D Secure as the way to implement the SCA requirement for online credit card transactions, as stated in another opinion, dated 21 June 2019:

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