--- title: "EBA Q&A 2018_4057 — Q&A — SCA at vending machines without PIN pad [Final Q&A]" shortTitle: "EBA Q&A 2018_4057 — Q&A — SCA at vending machines without PIN pad [Final Q&A]" answer_id: EBA_QA_2018_4057 status: "Final Q&A" type: qa instrument_type: qa authority: EBA binding: false binding_character: non_binding legal_status: in_force regulation: "PSD2" psd2_level3: true mica_level2: false legal_basis: "Article 97 PSD2" date: 9 August 2019 source_link: https://www.eba.europa.eu/single-rule-book-qa/qna/view/publicId/2018_4057 lifecycle: "Final Q&A" text_version: "EBA Q&A register, 9 August 2019" source_url: "https://www.eba.europa.eu/single-rule-book-qa/qna/view/publicId/2018_4057" check_status: matched verified: true last_checked: 2026-10-26 checked_against: "the EBA publication" source: prepared_by: "EBA" published_by: "EBA" published_in: "EBA Single Rulebook Q&A tool" evidence: prepared_by: "Answer prepared by the EBA." locator: "EBA Q&A register entry 2018_4057, field 'Answer prepared by'" document_type: "qa_answer" legal_nature: "not_legislation" addressees: "not stated in the document" dates: published_on: "2019-08-09" question_submitted_on: "2018-06-28" locators: published_on: "EBA Q&A register entry 2018_4057, field 'Final publishing date'" question_submitted_on: "EBA Q&A register entry 2018_4057, field 'Submission date'" lifecycle_label: "Final Q&A" --- **Answer by the EBA, published in its Q&A tool · not legislation · published 9 Aug 2019 [Final Q&A]** *Final Q&A · EBA Q&A register, 9 August 2019 · Checked against the EBA publication on 26 Oct 2026 · [Official source](https://www.eba.europa.eu/single-rule-book-qa/qna/view/publicId/2018_4057)* | | | |---|---| | **Full title** | EBA Q&A 2018_4057 — Q&A — SCA at vending machines without PIN pad \[Final Q&A\] | | **Prepared by** | EBA | | **Published by** | EBA, in the EBA Single Rulebook Q&A tool | | **Reference** | EBA_QA_2018_4057 | | **Document type** | Q&A | | **Legal nature** | Not legislation | | **Addressees** | Not stated in the document | | **Dates** | Published 9 August 2019; question submitted 28 June 2018 | | **Legal basis** | Article 97 PSD2 | | **Related instruments** | None recorded | | **Text on this page** | Word for word — the full text of the EBA publication | **SCA at vending machines without PIN pad** ### Question Do transactions at vending machines without PIN pad require Strong Customer Authentication (SCA)? ### Background Transactions at vending machines without PIN pad should not require SCA. The issuer is unable to perform SCA and can only decline transactions if the contactless exemption under Article 11 does not apply. Recital 11 of the RTS reads: "It is also appropriate to establish an exemption for the case of electronic payment transactions initiated at unattended terminals where the use of strong customer authentication may not always be easy to apply due to operational reasons (e.g. to avoid queues and potential accidents at toll gates or for other safety or security risks).” The same rationale of “operational reasons” should apply to transactions at vending machines. The very low amounts of these transactions, the impossibility to apply SCA and the need for a fast purchase would justify an exemption. *** ### Answer Article 97(1)(b) of PSD2 states that Member States shall ensure that a payment service provider applies strong customer authentication (SCA) where the payer initiates an electronic payment transaction. This is the case for payment transactions at vending machines unless the transaction qualifies for an exemption as defined in Commission Delegated Regulation (EU) 2018/389. The Delegated Regulation defines two exemptions applicable to proximity payments, one for contactless payments at point of sale, under Article 11, and another for electronic payment transactions at unattended terminals for transport fares and parking fees under Article 12. The contactless payment exemption may apply to those vending machines where contactless payments can be used. However, the exemption under Article 12 of the Delegated Regulation only applies to ‘transport fares and parking fees’ and does not apply to vending machines providing other goods and services, such as providing the facility to buy food or beverages. The Delegated Regulation also foresees a number of exemptions for remote payment transactions. In the case where the payment transaction is carried out remotely (e.g. initiated through a mobile phone) without any link to the physical vending machine, such transactions could be considered remote transactions and potentially benefit from other exemptions from the application of SCA under the Delegated Regulation. *** **Source:** [EBA original document](https://www.eba.europa.eu/single-rule-book-qa/qna/view/publicId/2018_4057) ## Related Level 1 articles - [Article 97 — Authentication](../../../articles/97.md)