--- title: "EBA Q&A 2021_5845 — Q&A — Ability of Payee’s PSP to apply exemptions from SCA [Final Q&A]" shortTitle: "EBA Q&A 2021_5845 — Q&A — Ability of Payee’s PSP to apply exemptions from SCA [Final Q&A]" answer_id: EBA_QA_2021_5845 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 98 PSD2" date: 27 January 2023 source_link: https://www.eba.europa.eu/single-rule-book-qa/qna/view/publicId/2021_5845 lifecycle: "Final Q&A" text_version: "EBA Q&A register, 27 January 2023" source_url: "https://www.eba.europa.eu/single-rule-book-qa/qna/view/publicId/2021_5845" 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 2021_5845, field 'Answer prepared by'" document_type: "qa_answer" legal_nature: "not_legislation" addressees: "not stated in the document" dates: published_on: "2023-01-27" question_submitted_on: "2021-05-12" locators: published_on: "EBA Q&A register entry 2021_5845, field 'Final publishing date'" question_submitted_on: "EBA Q&A register entry 2021_5845, field 'Submission date'" lifecycle_label: "Final Q&A" --- **Answer by the EBA, published in its Q&A tool · not legislation · published 27 Jan 2023 [Final Q&A]** *Final Q&A · EBA Q&A register, 27 January 2023 · Checked against the EBA publication on 26 Oct 2026 · [Official source](https://www.eba.europa.eu/single-rule-book-qa/qna/view/publicId/2021_5845)* | | | |---|---| | **Full title** | EBA Q&A 2021_5845 — Q&A — Ability of Payee’s PSP to apply exemptions from SCA \[Final Q&A\] | | **Prepared by** | EBA | | **Published by** | EBA, in the EBA Single Rulebook Q&A tool | | **Reference** | EBA_QA_2021_5845 | | **Document type** | Q&A | | **Legal nature** | Not legislation | | **Addressees** | Not stated in the document | | **Dates** | Published 27 January 2023; question submitted 12 May 2021 | | **Legal basis** | Article 98 PSD2 | | **Related instruments** | None recorded | | **Text on this page** | Word for word — the full text of the EBA publication | **Ability of Payee’s PSP to apply exemptions from SCA in credit transfers** ### Question Can the Payee’s Payment Services Provider (PSP) apply an exemption from strong customer authentication (SCA) in credit transfers that are initiated through the payee? ### Background The “Opinion of the European Banking Authority on the implementation of the RTS on SCA and CSC” issued on June 13th, 2018, includes a table in paragraph 40 (“Table 2”) that summarizes in which cases PSPs can apply the different exemptions mentioned in Articles 10-18 of the RTS on SCA and CSC. According to this table, the Payee’s PSP cannot propose to apply any exemption at all if the payment is done by credit transfer. We understand that this is because credit transfers are typically initiated by the payer, so by the time the transaction reaches the Payee’s PSP the SCA has already been performed (or an exemption applied by the Payer’s PSP), and therefore it doesn’t make sense that the Payee’s PSP considers applying an exemption. However, there are use cases in which a payment articulated via a credit transfer is initiated through the payee. For example, in Request to Pay, or in certain e-commerce payment services such as Bizum where the ecommerce payment is channeled by the same virtual Point of Sale (POS) as cards. In those cases, it does make sense that the Payee’s PSP may want to apply an exemption from SCA if the right conditions are met. Of course, as in all other cases, the Payer’s PSP will make the ultimate decision whether to accept the exemption, apply SCA, or decline the transaction. *** ### Answer Article 97(1)(b) of Directive (EU) 2015/2366 (PSD2) prescribes that the payment service provider (PSP) shall apply ‘strong customer authentication (SCA) where the payer initiates an electronic payment transaction’. Article 4(24) of PSD2 defines a 'credit transfer' as a 'payment service for crediting a payee's payment account with a payment transaction or a series of payment transactions from a payer's payment account by the payment service provider which holders the payer's payment account, based on an instruction given by the payer'. Q&A 5247 clarified that credit transfers are by definition payer-initiated electronic payments and that SCA applies to them in accordance with Article 97(1)(b) of PSD2. In addition, table 2 of the Opinion on the implementation of the RTS on SCA&CSC (EBA-Op-2018-04) indicated that payee’s PSPs cannot apply an exemption from SCA for credit transfers. Accordingly, the payee's PSP cannot apply an exemption from SCA when the payer initiates a credit transfer, even if the transaction is initiated through the payee. *** **Source:** [EBA original document](https://www.eba.europa.eu/single-rule-book-qa/qna/view/publicId/2021_5845) ## Related Level 1 articles - [Article 98 — Regulatory technical standards on authentication and communication](../../../articles/98.md)