EBA consultation to the regulatory technical standards on strong customer authentication and secure communication as the key objective of the PSD2

Bitkom welcomes the opportunity to answer the EBA Discussion Paper on future Regulatory Technical Standards on strong customer authentication and secure communication under PSD 2.
Bitkom believes that the regulatory framework in the European Union provides an adequate environment for business and innovation in the area of e- and m-commerce, including payments. EU legislation on payments, e-money and consumer rights, among others, is among the most advanced globally, and serves as examples for many countries around the world that want to achieve similar market integration, innovation and prosperity. This holds also for the European payments market. We strongly support the initiative to foster a single European market for retail payments and protection of consumer interests. We are certain that the prospect of economic reward is the key driver for innovation.
The pace of development in payments innovation has increased significantly with the development and increasing prevalence of the internet and more recently multi-functional smart phones. The evolution is still ongoing and any final scenario cannot be predicted. Regulatory neutrality must be respected as regards the various types of payment systems and methods. BITKOM therefore insists that any regulatory interference deemed necessary must not disrespect regulatory neutrality.