Obstacles

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. 

Implementation of the Open Banking Technical Specifications and Security Profiles, together with use of the conformance tools to test and validate conformance, will help ASPSPs remove technical obstacles for TPPs. Furthermore, the Customer Experience Guidelines and Customer Experience Guidelines Checklist (the CEG) have been created to support this requirement from the perspective of the customer journey implemented by the ASPSP for their dedicated interface(s).

The Operational Guidelines and the Operational Guidelines Checklist (this document) contain additional requirements and recommendations for ASPSPs which, if implemented, can be utilised to further reduce obstacles relating to the overall performance and functionality of the ASPSP’s interface.

The combination of the CEG and the OG can be used to support the relevant requirements of Guideline 5 and assist an ASPSP’s application for an exemption.

ASPSPs should also give consideration to the “user experience” for a TPP in its direct interactions with ASPSPs, such as dynamic client registration or communication of changes to specifications.