The Berlin Group has developed an ISO 20022-based, joint, Pan-European API standard to facilitate access to bank accounts by third party providers. If you take a look at the list of members, it is apparent that nearly a third of them come from Germany. Does this mean that the interest among other European financial institutions in a common interface standard is so minor? That they will invent their own APIs? Or that they will be interested in the finished product offered by the Berlin Group?
That there are a large number of members from Germany is simply attributable to the fact that we campaigned for a uniform standard very early on. You can almost say that the German banks, or the German Banking Industry Committee, are among the founding members of this initiative. Nevertheless, organizations from twenty EU nations are meanwhile represented, which is tremendous considering that it is a voluntary initiative. Looking at Europe, you will find that there are only five initiatives that have developed a standard: besides the Berlin Group, there are initiatives from Great Britain, France, Poland and Slovakia. Of these five initiatives, four are nationally oriented and only the one from the Berlin Group is actually Pan-European. That was the main impetus for our support for the Berlin Group.
How do you estimate the chances that agreement will be reached for a single international European solution? To what extent do these national standards differ from one another?
There are certainly efforts to merge the standards. The first harmonization efforts between the French standard and the Berlin Group, as well as in the direction of Poland, have already taken place. It was recognized that the uniform interface is better than proprietary solutions, regardless of whether from a bank or nationally. The European Commission also supports the idea of a uniform interface. However, there are indeed also national characteristics to be considered, such as with the British market, where the competition authorities are requesting that the nine largest banks open themselves up to competition. The requirements there go beyond the PSD2.
Are all requirements and the necessary investment security for the successful implementation of PSD2 otherwise in place?
Not quite. The RTS leaves it up to each bank to decide whether to offer a dedicated interface or whether to open the customer interface and, for example, online banking. At the same time, the RTS requires banks that offer a dedicated interface to also offer an emergency solution, or fallback access. The problem with this is that it involves a second interface, which would cause twice the investment costs among the banks. Under these requirements, no bank will offer standardized, dedicated interfaces, but their own solutions in the form of an adapted customer interface, which is precisely the opposite of what is intended to be achieved with an API standard interface. There is meanwhile an option in the RTS for a bank to free itself from this fallback solution by requesting an exemption from the national bank supervisory authority. This, however, is linked with the meeting of specific requirements for the interface, and the criteria have not yet been established in detail. We are slowly running out of time.