Availability and performance
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The following tables set out:
Regarding the latter, the RTS is clear that ASPSPs must “…ensure that the dedicated interface offers at all times the same level of availability and performance, including support, as the interfaces made available to the payment service user for directly accessing its payment account online…” and “…define transparent key performance indicators and service level targets, at least as stringent as those set for the interface used by their payment service users both in terms of availability and of data provided in accordance with Article 36” (RTS Arts. 32(1) and (2)).
While in most cases the availability and performance standards of an ASPSP’s customer channel should be a sufficient proxy for TPP and customer expectations, parity with a poorly performing customer interface could lead to poor TPP and customer experiences and outcomes.
For this reason we believe that an effective Open Banking ecosystem needs ecosystem-wide benchmarks, referred to as the “OBIE Recommended Benchmark”:
ASPSPs must, as per EBA/FCA requirements, ensure (at least) parity between the availability and performance of their best performing PSU interface and that of their dedicated interface.
Separately, to ensure an appropriate base level of availability and performance of the dedicated interface, ASPSPs should aim to adhere to the OBIE Recommended Benchmark, unless (in the unlikely event) that this would bring the dedicated interface below the availability and performance of the PSU interface.
1 More information can be found here: https://www.openbanking.org.uk/providers/account-providers/api-performance/
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