--- title: "EBA Q&A 2020_5135 — Q&A — Payment Initiation Scope and Trusted Beneficiaries [Final Q&A]" shortTitle: "EBA Q&A 2020_5135 — Q&A — Payment Initiation Scope and Trusted Beneficiaries [Final Q&A]" answer_id: EBA_QA_2020_5135 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: 15 January 2021 source_link: https://www.eba.europa.eu/single-rule-book-qa/qna/view/publicId/2020_5135 lifecycle: "Final Q&A" text_version: "EBA Q&A register, 15 January 2021" source_url: "https://www.eba.europa.eu/single-rule-book-qa/qna/view/publicId/2020_5135" 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 2020_5135, field 'Answer prepared by'" document_type: "qa_answer" legal_nature: "not_legislation" addressees: "not stated in the document" dates: published_on: "2021-01-15" question_submitted_on: "2020-02-18" locators: published_on: "EBA Q&A register entry 2020_5135, field 'Final publishing date'" question_submitted_on: "EBA Q&A register entry 2020_5135, field 'Submission date'" lifecycle_label: "Final Q&A" --- **Answer by the EBA, published in its Q&A tool · not legislation · published 15 Jan 2021 [Final Q&A]** *Final Q&A · EBA Q&A register, 15 January 2021 · Checked against the EBA publication on 26 Oct 2026 · [Official source](https://www.eba.europa.eu/single-rule-book-qa/qna/view/publicId/2020_5135)* | | | |---|---| | **Full title** | EBA Q&A 2020_5135 — Q&A — Payment Initiation Scope and Trusted Beneficiaries \[Final Q&A\] | | **Prepared by** | EBA | | **Published by** | EBA, in the EBA Single Rulebook Q&A tool | | **Reference** | EBA_QA_2020_5135 | | **Document type** | Q&A | | **Legal nature** | Not legislation | | **Addressees** | Not stated in the document | | **Dates** | Published 15 January 2021; question submitted 18 February 2020 | | **Legal basis** | Article 97 PSD2 | | **Related instruments** | None recorded | | **Text on this page** | Word for word — the full text of the EBA publication | **Payment Initiation Scope and Trusted Beneficiaries** ### Question Should non-payment accounts be listed as trusted beneficiaries where they are exempted from Strong Customer Authentication (SCA) as Beneficiaries of a Payment Transaction? ### Background Many Account Information Service Providers (AISPs) are providing specific Payment Initiation Services (PIS) for Personal Finance Management use cases and obtained their PIS license specially to be able to maintain their services. One of their service main functionality is allowing the PSU to transfer funds from his Payment Account to his Non-Payment Accounts (such as Savings). In answer to Third Party Provider (TPP) information requests, most of Credit Institutions confirm that their dedicated interfaces are supporting Payment Initiation from a Payment Account to an Internal Non-Payment Account which seems compliant with Regulation and with Paragraph 45 of EBA Opinion on RTS on SCA and CSC. On the other hand, most of them consider that those Non-Payment Accounts are not in the scope of Trusted Beneficiaries although they are exempted from Strong Customer Authentication. Where a list of Internal Accounts is made available to the Payment Service User (PSU) in his Direct Access Interface as Beneficiaries, the information of these beneficiaries shall be available in the Dedicated Interface, otherwise TPP have no possibility to identify these accounts as Beneficiaries in the PIS context. *** ### Answer Article 13 of the Commission Delegated Regulation (EU) 2018/389 does not specify the type of payees that can be included in the list of trusted beneficiaries. This means that there are no restrictions on the type of accounts that can be included in the list of trusted beneficiaries, provided that they allow the receipt of payment transactions. In relation to the above, non-payment accounts can be included in the list of trusted beneficiaries under Article 13 of the Delegated Regulation. In the specific case where the payer initiates a payment from his payment account to another non-payment accounts held within the same payment service provider (PSP), the PSP may also apply the exemption under Article 15 of the Delegated Regulation. Q&A 2018\_4128 clarified that “as it is ultimately the ASPSP (account servicing payment service provider) that applies strong customer authentication (SCA) or decides whether or not to apply an exemption, including the exemption on trusted beneficiaries as stated in Article 13 of the Commission Delegated Regulation (EU) 2018/389, the information as to whether or not a payee is on the list of trusted beneficiaries is not necessary for the provision of the PIS (payment initiation service). This may be different if the ASPSP and the PISP (payment initiation service provider) agree that SCA is performed by the PISP and if it is agreed that the PISP is allowed to apply the exemption in Article 13. Finally, ASPSPs do not have an obligation to provide to account information service providers or PISPs a list of the non-payment accounts of the payment service user, because the requirements of Directive 2015/2366/EU (PSD2) on access to accounts data apply only to payment accounts. *** **Source:** [EBA original document](https://www.eba.europa.eu/single-rule-book-qa/qna/view/publicId/2020_5135) ## Related Level 1 articles - [Article 97 — Authentication](../../../articles/97.md)