The European Payments Council (EPC) released version 1.1 of the Payment Account Access (SPAA) scheme rulebook on 26 June 2023. This updated version replaces the previous version 1.0, which was published in November 2022. The new rulebook will become effective on 30 November 2023.
The SPAA scheme aims to provide a comprehensive set of rules and standards for banks and third-party providers to access and utilise payment account information within the SEPA area. While the PSD2 directive outlines general requirements for accessing banking data, the SPAA rulebook fills the gap by offering a more specific and detailed framework. It includes technical and operational guidelines for accessing account information, addressing aspects such as authentication, security, privacy, and liability. The SPAA scheme also introduces optional premium API-based services, such as multiple payments, payment certainty mechanisms, e-mandates, and future-dated and dynamic recurring payments. These services go beyond the requirements of PSD2 and provide additional revenue opportunities for banks. The SPAA scheme will operate through Payment Initiation Services (PIS) via the SCT Inst rails, with enrollment for banks and third-party providers opening on 1 September 2023.
i. Asset Holders (AH): this can be seen as a generalisation of the PSD2 ASPSP concept. An AH is an institution that holds payment-related transaction assets and data assets for its customers, the Asset Owners (AO). It can be a Credit Institution, an E-money Institution or a Payment Institution.
ii. Asset Brokers (AB): likewise, a generalisation of the PSD2 TPP concept. It is an institution that accesses transactions and data assets held by Asset Holders for their customers, the Asset Users (AU). Of course, this role is not limited to PSD2 TPPs, but can also be played by Asset Holders themselves.
iii. Asset Owners: individuals or firms that have a contract with an Asset Holder to manage, or 'hold', their payment transactions and related information. In other words, there are Asset Holder customers. It can also be seen as a generalisation of the PSD2 PSU concept.
iv. Asset Users: individuals or firms that have a contract with an Asset Broker to access transaction or information assets held by an Asset Holder, with the appropriate consent of the Asset Owner. The Asset User could be a different individual or legal entity in some scenarios, such as a merchant requesting an Asset Owner to authorise a payment for the exchange of goods or services. However, in other scenarios, it could also be the Asset Owner himself - for example, an individual in a Personal Financial Management scenario or a legal entity in an accounting services scenario.
The main reason for adopting a 'fresh' and more holistic terminology for the actors was the ambition to facilitate the evolution from payment or payment-related services, to finance beyond payments and even beyond finance. FIDA would be a good example. Regardless of whether this happens within SPAA or somewhere else, we believe the model will greatly facilitate the transition to the European Data space. Only the relationship between Asset Holders and Asset Brokers is governed by the SPAA scheme rules. Both the relationship between Asset Holders and Asset Owners and the relationship between Asset Brokers and Asset Users are outside the scope of the SPAA scheme.
Our remaining challenge is to land the business conditions and have them approved by the SPAA MSG and subsequently by the EPC Board. The Rulebook V 1.1 is there, but the so-called default remuneration for access and premium functionalities is still a work in progress. These default fees apply unless scheme participants bilaterally agree to a lower fee and are paid by the Asset Broker to the Asset Holder via the scheme manager.
Once the fees are made public, market participants can make their calculations and decide whether or not to invest in SPAA and become a scheme participant. One of the things we will discuss in the SPAA MSG is what the rollout strategy should be, perhaps including pilots. What we have already been doing, and this interview is part of that, is communicating about SPAA and its potential and creating awareness. We do not want to create a ‘zombie scheme’ that nobody uses. Our ambition is to facilitate a lively and vibrant European Open Banking ecosystem.
SPAA distinguishes between 'basic' services, i.e. services within the scope of PSD2 and which Asset Holders are still obliged to provide for free as ASPSPs through their PSD2 compliance API. However, if these services are offered and consumed through SPAA, they will carry a small access fee as the SPAA community acknowledges that there is inherent value when these services are offered through the scheme. This is a sensitive and sometimes confusing issue, which we have also discussed with the Commission. We believe a good compromise was struck here, and we will see how this plays out over time.
Then, there are premium services, which would be services that go beyond the scope of PSD2 and thus do not have to be offered for free. In the case of transaction services, these would be a host of transaction services, such as dynamic recurring payments or payments to multiple counterparties, that would put account-to-account payments on par with, if not beyond, other (card-based) payment instruments especially if based on SCT Inst. For instance, you could now be able to do the equivalent of `card-on-file` transactions with account-to-account payments.
SPAA is a voluntary adherence scheme, and therefore needs to be attractive for both Asset Holders and Asset Brokers. The main challenge here are the business conditions within SPAA and the investments required to join SPAA. If the business conditions are attractive, and the adherence costs are reasonable to both parties, we see no reason why there should not be a massive take-up. Why would an Asset Holder not offer basic transaction and information services through SPAA that he will otherwise have to offer for free through a PSD2 compliance API? Likewise, why would an Asset Broker not be willing to pay a small amount for an industrial-quality API that offers significantly enhanced services? The best demonstration of the keen interest from many sides of the industry is probably the fact that we had to establish a dedicated SPAA Scheme Interest Group beyond the SPAA Multi-Stakeholder Group itself, in which Asset Brokers and Asset Holders are represented in a balanced way. A multitude of market participants wanted to be closely involved and informed of our progress.
Any interested party that complies with the eligibility criteria as described in the rulebook may apply to become a SPAA scheme participant by submitting to the EPC a signed version of the Adherence Agreement and Schedule information to the Adherence Agreement (both documents are included in Annex I of version 1.1 of the rulebook). By signing the adherence agreement, participants agree to respect the rules described in the rulebook.
Participants can commit to participating in the scheme in the role of Asset Holder, or in the role of Asset Broker or in both roles by exchanging payment-related data and transactions in the context of ‘value-added’ (Premium) services under the scheme and processing them according to the rules of the scheme.
The EPC secretariat will objectively determine whether or not the applicant is able to satisfy the eligibility criteria and make a positive or negative decision regarding the application.
Moreover, the EPC secretariat will also maintain and publish on its website a Scheme register of Participants which contains the applicant type (Asset broker vs Asset Holder (including category)), name, identifier, contact address and other details determined by the EPC in respect of each participant.
The SPAA scheme, along with its default remuneration model, lays the foundation for market participants to provide attractive services to end users, both corporates/merchants and consumers. That means that the default remuneration model must leave enough room for Asset Brokers to provide such services in a competitive environment to the market.
The model is based on a carefully crafted and objective cost calculation model which is being developed by an external economic consultant. To a large extent, we are navigating through yet uncharted waters here, and only by taking SPAA to the market we will be able to find out if the remuneration model is fit for purpose. The market is always right, as they say, and the only way to find out is by taking action.
Of course, this dilemma was recognised by the SPAA MSG. Hence, the default fees are the initial default fees which can be recalibrated from time to time, depending on market developments and based on the development of the scheme.
From our perspective, it would be ideal for all ASPSPs that have aligned with the EPC SCT and/or SCTinst schemes to also adopt SPAA. Why? It is important to realize, as we explained above, that ASPSPs will still have to provide free open banking compliance APIs under PSD2, and in future, under PSD3/PSR, if they choose not to engage with SPAA. So, aside from operational, resource-related or priority-based considerations, it is hard to imagine a good reason for ASPSPs not to become a SPAA participant.
While PSD3/PSR are only proposals subject to potential evolution within the political process, we don't foresee any negative implications for the SPAA scheme. Moreover, the Commission holds an observer role in the SPAA MSG, and we have been reassured that there is nothing in the PSD3/PSR proposals that would materially impact or hinder the SPAA scheme.
As said before, we firmly believe that the FIDA framework for open finance data fully recognises the SPAA four-corner model by mandating a scheme model, with room for a compensation model inside it.
Some appear to perceive EPI and SPAA are mutually exclusive, and we have discussed this with the CEO of EPI, as we believe this perspective is not accurate. Just like SPAA, EPI has the ambition to build a European payment solution, and, in our view, EPI and SPAA are complementary. EPI is a voluntary coalition of European ASPSPs developing a suite of A2A payment solutions as a true alternative to non-European solutions.
However, it`s important to note that EPI members are still required to offer PSD2 compliance APIs and, in a few years’ time, to be PSD3/PSR compliant. Therefore, we believe the same logic to join SPAA would apply to all ASPSPs irrespective of whether they participate in EPI or not.
Gijs Boudewijn (1958) is currently General Manager at the Dutch Payments Association (DPA). He has extensive experience in domestic as well as international payments related issues. Closely involved in PSD2/3 matters, open banking and the RTS of the EBA, instant payments and digital euro. He is Chair of the Legal Support Group of the European Payments Council (EPC) after serving several terms as Board member, and Vice-Chair of the Payment Expert Group of the European Banking Federation (EBF, after having served 3 terms as Chair). He is Vice-Chair of the European Card Payments Association (ECPA) and chairs the Payments Working Group of the International Banking Federation (IBFed). Last, he is a member of the Payment Systems Market Expert Group (PSMEG) of the European Commission and co-Chair of the EPC’s SEPA Payment Account Access scheme Multi Stakeholder Group on behalf of the credit sector associations. He is a regular speaker and panelist at national and international conferences on strategic and regulatory payments related issues, instant payments, new technologies and open banking.
Arturo is the Vice-Chair of ETPPA, the European Third Party Providers Association, and co-Chair of the SPAA initiative. Before that, he was the CEO of Eurobits, the company that introduced Account Information Services in Europe in 2003. Arturo launched Eurobits, went through an MBO and ultimately sold the company to Tink, which is now a part of Visa. His career has been marked by his role in the introduction of high-tech products and services to the financial sector. Arturo is also the Chair of AEFI, the Spanish Fintech and Insurtech Association, and represents the ETPPA at the ERPB and the EPC where he is a board member.
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