Background
Pursuant to Article 33(3) of the RTS on SCA and CSC, both ASPSPs and the TPPs referred to in Article 30(1) must report problems relating to the dedicated interfaces described in that provision to their respective competent national authorities.
The dedicated interfaces that ASPSPs provide to TPPs for accessing payment accounts must not create 'obstacles' to the provision of payment initiation services and account information services (RTS on SCA and CSC, Article 32(3)). In addition, ASPSPs must resolve any issues relating to such interfaces without undue delay (Article 33(6)(d)).
The reporting of issues
Where a TPP encounters problems with an interface for access to a payment account, it should first contact the relevant ASPSP through the complaints procedure established by that ASPSP.
If the TPP and the ASPSP are unable to reach a solution that complies with the applicable legal and regulatory requirements, the matter may be reported to DNB. Before doing so, you are requested to complete the ASPSP's complaints procedure (see the criteria set out in the DNB complaint form, tab 'Read_Me INFO'). You should also ensure that there is a clear legal basis on which the ASPSP can reasonably be expected to remedy the identified issue with the interface.
The completed DNB complaint form (tabs A.1 and A.2) may be submitted to denederlandschebank@dnb.nl or to your account supervisor.
If there is uncertainty regarding the practical interpretation or application of the legal requirements applicable to the interface, you may make use of the European Banking Authority (EBA) Q&A process, so that the matter can be clarified on a European level.
What happens after you submit a report to DNB?
DNB takes your report into account in its supervision of compliance with the legal requirements applicable to interfaces for access to payment accounts. DNB may contact you to request additional information.
Please note: DNB is the competent authority for issues relating to interfaces of ASPSPs that are supervised by DNB. TPPs wishing to report problems concerning an interface of an ASPSP that is not supervised by DNB should contact the competent authority responsible for supervising that ASPSP.
