Guidance for ASPSPs to demonstrate that their dedicated interface has been designed and tested in line with EBA requirements, that has been appropriately stress tested and to evidence wide usage by TPPs.
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This chapter provides guidance on the overall expectation for ASPSPs to demonstrate that their dedicated interface has been designed and tested in line with EBA requirements; that has been appropriately stress tested; and to evidence wide usage by TPPs.
Open Banking Limited (OBL) deems this essential in order for ASPSPs to successfully deliver the necessary functionality for the Open Banking ecosystem and to facilitate the creation of seamless customer experiences, which do not constitute obstacles for the provision of TPP services.
Open Banking Limited (OBL) considers that the implementation of effective design and testing (including stress testing) and the creation of obstacle-free customer journeys will provide TPPs with the confidence to offer their service to their customers with the knowledge that an ASPSP’s dedicated interface will support rather than hinder the provision of their service.
The EBA Guidance means that ASPSPs must ensure consistent engagement with TPPs within their design and testing processes so that issues are identified and rectified as early as possible. Robust stress testing will ensure that the dedicated interface is capable of dealing with not only anticipated demands but with higher-than-usual peak periods. Wide usage of the dedicated interface is required to show that it is capable of supporting a diverse set of TPP business models and use cases.
Open Banking Limited (OBL) has also briefly outlined what ASPSPs need to consider so as not to present obstacles to TPPs. This is covered more extensively within the Customer Experience Guidelines1.
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The Open Banking Standard was developed by Open Banking Ltd (OBL), the Implementation Entity described in the CMA Order, over a period of 18 months in collaboration with nine of Europe’s largest financial institutions as well as 500+ representatives from other ASPSPs, TPP communities, PSD2 and consumer stakeholder groups, and prominent fintech leaders.
ASPSPs are required to provide a Testing Facility to allow authorised and pre-authorised1 TPPs to undertake connection and functional testing of their products and services using non-PSU data. Issues identified in the testing process are useful to ASPSPs, alerting them to potential issues with their production environment.
Stress testing should either be conducted on the production interface (and underlying production systems) and / or staging/pre-production systems which have similar infrastructure, so there can be certainty that the test results will represent what will happen in a real-word scenario.
The Final EBA Guidelines have clarified that the wide usage requirements not only include the number of TPPs that make use of the dedicated interface but also the number of successful responses of ASPSPs to TPP requests the number of available TPPs and the results of testing, including the resolution of any issues that have been identified.
EBA Guideline 5 places a requirement on ASPSPs to ensure that their dedicated interface does not create obstacles for the provision of services by PISPs, AISPs and CBPIIs.
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