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Note to UK ASPSPs concerning eIDAS revocation statement by the EBA

A look at three possible options concerning the eIDAS revocation statement by the EBA

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EEA registered TPPs

EEA registered TPPs will still be able to access accounts held by UK ASPSPs after 31 December 2020 using their eIDAS certificates under the FCA’s temporary permissions regime (TPR).

UK registered TPPs

UK registered TPPs will not be able to access EEA based ASPSPs after 31 December 2020 unless they have also registered with an EEA National Competent Authority (NCA) and been issued with new eIDAS certificates based upon that registration.

UK based ASPSPs

After 31 December 2020, UK based ASPSPs will need to be able to accept access to account requests from EEA registered TPPs using eIDAS certificates for identity verification.

UK based ASPSPs may be able to continue accepting access to account requests from UK registered TPPs that have been issued with OBIE certificates (OBWAC and OBSealC) if the OBIE disassociates the OB certificates from the TPPs’ old eIDAS certificates and does not revoke the OB certificates when the eIDAS certificates are revoked.

UK based ASPSPs may also be able to accept access to account requests from UK registered TPPs that have been issued with Extended Validation certificates and their Authorisation number (i.e. PSDGB-FCA-1234567) is recorded in the “Other Name” field of the X.509 EV certificate. If they change their TPP identity validation policy accordingly and the FCA agrees that this is a valid TPP identity mechanism.

Konsentus Verify

Any ASPSP using the Konsentus Verify service will be able to validate the identity and authorisation status of a TPP that has either presented an eIDAS certificate, OB certificate or an EV certificate (as described above) after 31 December 2020.

This is subject to the results of the FCA’s consultation with the industry and the conclusions they come to. We expect a statement from the FCA before the end of August confirming the identity mechanisms that UK ASPSPs can use to validate TPPs after 31 December 2020.

Further information on the EBA statement on the end of the transitional arrangements between the EU and the UK visit: Konsentus response to EBA comments on a no-deal Brexit

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