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.
For the purposes of showing TPP involvement in the design of the dedicated interface, as per Section 3.2.1, we believe that given the level of engagement with TPPs in the design of the OBIE Standard, that an ASPSP implementing them as designed (i.e. without deviation) can refer to this as one source of supporting evidence.
For the matter of testing, this will need to be done on an individual ASPSP basis. In the development of the OBIE Technical Standard, the information sharing between TPPs and ASPSPs has been extremely valuable for both parties. Based on this, we are convinced that without extensive TPP input a dedicated interface of sufficient quality cannot be built, and therefore strongly endorse the EBA’s requirements here i.e. three months of live production for TPPs to provide services to their customers (noting this can run concurrently with testing).
Given this, we would note the changes made to the final EBA Guidelines regarding wide usage and “widely used” and the types of evidence NCAs are required to consider to assess under EBA Guideline 7.1.
If any ASPSP is unable to find TPPs with which to design and test their interfaces, we would encourage them to contact OBIE and we will attempt to find appropriate TPP partners. OBIE provides a ‘buddying’ service for enrolled ASPSPs to facilitate this. ASPSPs should not rely solely on the engagement of TPPs in the development of the OBIE Standard as proof of wide usage without evidence to show that the production environment was available for three months and significant effort was made to encourage TPPs to use the dedicated interface (as per EBA Guideline 7.1(b)).
ASPSPs should provide detailed evidence to demonstrate wide usage, over and above TPP numbers (e.g. in the form of research, testimonials or reviews from TPPs). For example:
- Testimonials from TPPs who have been involved with testing to confirm they are satisfied with the testing facility before moving to production.
- Description of major discrepancies between the numbers of TPPs involved in testing and production and their reasons for such discrepancies.
- Testimonials from TPPs who have used the dedicated interface for three months to confirm they are satisfied with the interface (i.e. with no significant ongoing defects).
- The number of requests submitted by TPPs using the dedicated interface that have been successfully responded to by an ASPSP.
- Details of communication to TPPs relating to availability for use of the dedicated interface.
OBIE notes that the results of testing related to issues and problems that were identified, including the resolution of those problems, will also be a factor that NCAs may consider for the purposes of assessing if an ASPSP has demonstrated ‘wide usage’ of their implementation.
When submitting evidence for an exemption application, ASPSPs could consider providing the details of contacts at TPPs that have been involved in testing when they have been given permission from the TPP to verify the information provided by the ASPSP.