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The Opinion sets the deadline to 31 December 2020 and prescribes the expected actions to be taken during the migration period.
This Opinion also recommends national competent authorities (NCAs) to take a consistent approach toward the SCA migration period across the EU and to require their respective payment service providers (PSPs) to carry out the actions set out in the Opinion.
In addition, the Opinion recommends that, where required, NCAs communicate to PSPs in their jurisdiction that the supervisory flexibility they have exercised does not represent a delay in the application date of the SCA requirements in PSD2 and the EBA's Technical Standards. Rather, it means that NCAs will focus on monitoring migration plans instead of pursuing immediate enforcement actions against PSPs that are not compliant with the SCA requirements.
Furthermore, the EBA notes that consumers will be protected against fraud as required by the law and NCAs should, therefore, communicate to their PSPs that the liability regime under Article 74 of the PSD2 applies and that issuing and acquiring PSPs are still liable for unauthorised payment transactions.