Key Indicators for Availability & Performance
- The regulatory requirements, as defined by EBA Guidelines 2.2, 2.3 and 2.4.
- For each requirement, OBIE guidelines to explain how these should be calculated by ASPSPs for the dedicated interface.
- For each requirement, an OBIE recommended benchmark for the dedicated interface.
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”:
- These benchmarks are based on feedback from the developer community for what a well performing API should support to enable PSU adoption and should be achievable by ASPSPs in most cases.
- Benchmark availability and AISP and PISP response times are based on the best performing endpoints of the CMA9 in the UK at the end of 20181 and factor in 1000 milliseconds (ms) per megabyte (MB) to cater for larger payloads.
- Benchmarks for CBPII response times are based upon international card schemes’ authorisation response times. It is noted that this benchmark would not apply to complex corporate models, but rather simple account models only.
- OBIE will review these benchmarks on a regular basis.
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/