Since the FCA announced a further 6 month delay in the UK’s deadline for Strong Customer Authentication there’s been a general expectation that the EBA would follow suit and relax the date for the EEA. However, it now appears that won’t happen – the 31st December 2020 remains the key date and there won’t be any further relaxation in the rules.
This hasn’t been officially announced but appears to have been the gist of a letter by the European Commission’s Executive Vice President Valdis Dombrovskis which makes clear that there’s no consideration in place for a delay and that, in the Commission’s view, the Coronavirus pandemic and the subsequent rise in e-commerce makes it more urgent to implement rather than less. It looks like the Commission is not for turning and with only a little over six months left to be prepared any merchant or payment service provider than hasn’t been planning for this is likely to be in full panic mode.
At one level it’s hard to disagree with the Commission’s position – the deadline has been shifted already from last September in order to accommodate the industry’s inability to implement in time. Although, in fairness, it ought to be noted that original requirements require a degree in semiotics to fully understand and clarifications have been fitful and, on occasion, too late. However, there’s a degree of real-world pragmatism missing from the decision – the last thing the European economy needs right now is an e-commerce cliff edge right in the middle of the busiest shopping period of the year.
The divergence between the UK and Europe also starts to raise some interesting questions. PSD2 applies to countries within the EEA and not to transactions starting or finishing outside – and as of January 1st 2021 the UK will be fully outside. PSD2 will apply within the EEA ex-UK and within the UK ex-Europe but, barring some kind of passporting agreement, not between them. One option for desperate European e-tailers may be to shift operations to the UK where the SCA deadline is a further 9 months away. Of course, the same applies in reverse: logically there ought to be a compromise, but those seem thin on the ground.
Overall, then, the message to all organisations involved in electronic payments is to assume that SCA will be enforced from January 1st next year and any firm that can’t support it should expect to see transactions declined. Merchants and PSPs may choose or may not be able to handle SCA but issuers will be ready and won’t want to be upsetting the regulators. For any companies out there that don’t know what to do come and talk to us, we can help guide you through the process – first by helping ensure you’re compliant and then by addressing the additional friction that SCA will introduce.
It isn’t too late to do something about SCA but it does very much look like we are at the eleventh hour.