Brussels, 11 April 2023,
The European Banking Federation, the European Association of Co-operative Banks, and the European Savings and Retail Banking Group, jointly known as the European Credit Sector Associations (ECSAs) welcome the ambitions presented in the European Commission’s proposal for a European Digital Identity (eIDAS 2.0).
The proposal will incentivise Member States to be more expedient in developing e-ID solutions with a wide scope of usage. Moreover, the European Digital Identity Wallet (EUDIW) will foster quicker onboarding processes and a better user experience.
It will also contribute to the further adoption of digital banking services. However, Recital 31 and Art. 12b.2 as adopted by the European Parliament and corresponding Art. 6db.2 of the Council’s General Approach are currently open to interpretation. The current wording seems to imply that the full payment sphere is included in eIDAS 2.0 on a mandatory basis.
We urge the European Parliament and the Council to re-consider their proposed wording during the trilogue negotiations. If widely used cards and payment specifications were included in the new EUDIW Infrastructure, huge investments would be required not only in the financial sector, but also for the overall acceptance network.
This could possibly result in disproportionate costs for merchants and service industries that accept card payments in accordance with the second Payment Services Directive (PSD2). In addition, deleting payments from the scope would also solve the general issue of liability banks would face. The proposal in its current form does not sufficiently address the question of liability, which impedes applying its provisions to payments.
This is why the ECSAs call upon the legislators to keep payments out of the scope of the Digital Identity Regulation. The ECSAs, therefore, recommend, in order to avoid the mandatory nature of the acceptance of the EUDIW in terms of strong customer authentication (SCA) on payments, limiting such mandatory acceptance to the verification of the user’s identity only.
About the ESBG: An advocate for a proportionate approach to banking rules. ESBG members have total assets of €6,38 trillion, provide 313 billion euros in loans to SMEs and serve 163 million Europeans seeking retail banking services. ESBG unites at EU level some 871 savings and retails banks, which together employ 610.000 people driven to innovate at more than 41.000 branches.
About the EBF: The European Banking Federation is the voice of the European banking sector, uniting 33 national banking associations in Europe that together represent some 3,500 banks – large and small, wholesale and retail, local and international – employing about 2,7 million people.
About the EACB: The European Association of Co-operative Banks (EACB) represents, promotes and defends the common interests of its 27 member institutions and of cooperative banks, with regard to banking as well as to cooperative legislation.
Source – the European Credit Sector Associations: PDF version