The new regulations concerning strong customer authentication and secure communication (RTS SCA & SC) under PSD II were published by the EU Commission on November 27, 2017. At first glance two points, in particular, come to mind: On the one hand, the requirements have been worded very generally, meaning that applying these rules to concrete payment processes will prove a major challenge to many market participants. On the other, the underlying security paradigms all appear to be inconsistent with one another. Even though these points were continually debated during the long consultation phase – including consultations, public hearings, numerous meetings involving market participants and the European Banking Authority (EBA), the final version of the RTS still does not provide sufficient clarity on the subject.

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