Category: Regulation

On 1 March 2022, the FCA updated its guidance on Strong Customer Authentication (SCA) to support the transition requirement of the UK- RTS Article 10A exemption including reconfirmation of consent by AISPs (pursuant to Article 36(6)).

This regulatory change comes into force on 26 March 2022. However, the FCA has provided the following updates: 

  1. ASPSPs to apply the exemption as soon as possible after 26 March 2022 with a view to the widespread adoption of the exemption by 30 September 2022.
  2. TPPs to be technically ready to reconfirm customer consent under Article 36(6) of the SCA-RTS as soon as possible after 26 March 2022. However, they may choose not to reconfirm consent until 30 September 2022 provided that SCA is applied at least every 90 days during that period.

The OBIE is supportive of these changes which we believe will minimise disruption to consumers and SMEs as the industry prepares to implement these changes.


The FCA has today published here its PS 21/19 (“policy statement”) for “Changes to the SCA-RTS and to the guidance in ‘Payment Services and Electronic Money – Our Approach’ and the Perimeter Guidance Manual” . This document proposed a number of modifications including to Article 10 of the UK- RTS, by replacing the requirement for the PSU to re-authenticate with their ASPSP every 90 days to allow AISP access  with the requirement for the PSU to reconfirm their consent with their AISP directly.

The OBIE will review the policy statement over the course of the next few days and decide on next steps including, for example, whether any changes are required to the Customer Experience Guidelines.  We will, of course, keep open banking participants informed.