confirmation on the availability of funds is requested, as well as clarifying the applicable liability regime for such services. i am aware that the market still has some concerns and that clarifications with respect to the psd2, and the rts in particular, have been requested. the ecb will continue to provide support and expertise in this field as an active observer in the api evaluation group, which was recently established by the european commission. beyond this, i am convinced that it is in your particular interest as payment service providers – and in the interest of the security of the retail payments market more generally – to implement the 1 / 3 bis central bankers'speeches rts and other related psd2 requirements as soon as possible. please do not wait 18 months until you are obliged to comply with the security requirements enshrined in the rts. take action soon, as these measures are necessary to mitigate threat scenarios of which you are well aware. for example, strong customer authentication solutions with dynamic linking of the authorisation to the specific amount and payee will help to prevent man - in - the - middle attacks. transaction and device monitoring is essential to identify unusual payment patterns and potential fraud cases. it is also essential to start offering well - functioning and reliable access interfaces to the payment service user accounts in order to protect the confidentiality and integrity of your customer information. it is also paramount that tpps be authorised or registered as soon as possible, and comply with all legal requirements at an early stage. tpps need to bear their share of the responsibility by testing and using the access interfaces in a prompt and cooperative fashion, and by contributing constructively to the ongoing efforts aimed at the standardisation of these interfaces. standardisation standardisation is a basis for the efficient and pan - european provision of payment services in an integrated market. already shortly after the adoption of psd2, members of the euro retail payments board ( erpb ) voiced concern that the legal requirements alone would not be sufficient for the provisioning of efficient and integrated pan - european payment initiation services ( pis ) and that the industry should agree on common technical, operational and business requirements to complement the legal requirements. “ business ” in this sense means, for instance, the processes for incident handling between psps but excludes commercial aspects. “ operational ” refers to matters such as a directory service that banks could address 24 / 7 to check whether a tpp contacting them is indeed still a licensed psp.

a bank can also be compliant with the rts by offering an adaptation of its customer online banking interface instead of a dedicated interface. such interfaces would meet the legal requirements, but would not meet the market needs of efficient and pan - european provision of payment initiation services. so i was disappointed when i heard that some banks seem to be seriously considering this option. i strongly encourage them to offer a dedicated interface, based on a standardised specification, as this is one pillar of successful pis. last, but certainly not least, the erpb extended the mandate of its working group on payment initiation services to follow up several common requirements related to operational and business elements, which together are the other pillar of successful pis. i appreciate the commitment that the banks have shown to this important task and expect to complete the work by june 2018. it is important that the api evaluation group and the erpb working group progress in parallel so that psps have clarity by the summer and can plan their investments that need to be made. then they can prepare for a timely implementation of psd2 and the rts and be ready for the competition that psd2 aims to foster. conclusion to conclude, i would strongly encourage european payment service providers to embrace the opportunities the psd2 provides for competition and innovation, to cooperate in the standardisation of apis that should preferably result in a single api, and to implement all the security requirements of the new directive and its rts as soon as possible, even before they become mandatory. i count on the full commitment of the european banking federation and the entire payments industry to work towards safe, efficient and innovative payment services. 3 / 3 bis central bankers'speeches