In our response to the EBA public consultation on amending RTS on SCA and CSC under PSD2, ACCIS notes that a consistent number of difficulties both for account information service providers (AISPs) and for open banking final users’ come from the process of strong customer authentication (SCA) which is often cumbersome. In that regard, ACCIS welcomes the focus that the EBA has placed on seeking to address the widespread concerns about the practicability of the current requirements around SCA, both in terms of the exemption for AISPs and further improvements of the SCA process itself.