Where are the Dutch statistics on PSD2?
Eppo Heemstra, Connective Payments
Five years ago, the European Commission approved the PSD2 rules to open up the Payments market and make room for further innovations. The pace and form in which PSD2 legislation came about varied widely across markets. Up-to-date figures are required to be able to follow the implementation. How often are payment data requested through API calls, and for what purpose? How current are the data, and how quickly can the applicant have access to it? What about availability? That is why the regulators (EBA, OBIE) imposed clear requirements on the parties from the start: periodic reports had to be produced to monitor the performance of the PSD2 infrastructure.
We examined the situation on the Dutch payments market.
But first, some abbreviations to clarify how PSD2 works.
- ASPSPs (Account Servicing Payment Service Providers, especially the banks) must make the payment data of their customers available to
- TPPs (Third Party Providers). These are the parties that use that data to develop new services. Of course under strict conditions. To name two, a TPP can only access the data if it is certified to do so, and customers must explicitly grant the TPP permission to use their payment data.
- ASPSPs and TPPs exchange data by means of standard APIs (Application Programming Interfaces).
- There are APIs to request payment data to consult, analyse, perform calculations, etc. The TPP needs a so-called AIS (Account Information Service) license for this.
- And there are APIs that allow the TPP to independently initiate payments on behalf of the customer. This requires a heavier license: a so-called PIS (Payment Initiation Service) license.
A PSD2 app in the making
Suppose you are a TPP. You are developing a smart app that performs calculations based on your customer’s income and expenses. With the help of Connective Payments, you have received a hard-won license from De Nederlandse Bank to collect the payment data from the relevant bank(s). You have convinced your customer of the added value of your app. He wants to share his payment details with you. You have successfully developed a technical API call. Finally you can go live! Then it is very important for you to have fast access to information like:
- How current, fast and how reliable are the APIs?
- How robust are they: how quickly are faults resolved, at what service levels?
- What happens in case of major incidents?
So, where do you find all that information?
Perhaps another question first: is your app aimed at the UK market or continental Europe?
Open Banking performance statistics in the UK
In a previous article I pointed out that the UK is further ahead than the European mainland in opening up the Payments market. Every month, the OBIE (Open Banking Implementation Entity) publishes an extensive factsheet about the numbers of API calls, the uptime of the banks and more relevant statistics. This monthly factsheet provides a great insight into how the market is developing and how the ASPSPs are performing and responding to the API calls they receive. Individual banks are required to be transparent about the number of API calls and about the failures, whether they are failed technical or business API calls.
Anyone interested gets a quick overview of the performance statistics. They give a good picture of where the market is going:
- The successful API calls at the 19 reported banks show a strong increase.
- In June 2021, there were more than 800 million successful AIS transactions. That is double from a year ago.
- The number of successful PIS transactions was 1.8 million in June 2021, compared to 280,000 a year ago.
PSD2 performance in mainland Europe
From the start of PSD2, the EBA insisted that API services should have the same performance requirements as the ASPSP’s own online payment accounts.
This means that no distinction would be made between the “own” use of the data and the use by the TPP. Things like contingency planning and maintenance windows had to be handled equally professionally.
In Guideline 3, the EBA requested ASPSPs to keep daily statistics on the availability and performance of the API interfaces, and to publish them in the form of a quarterly report.
Guideline 3: Publication of statistics
3.1 For the purpose of Article 32(4) of the RTS, the ASPSP should provide its competent authority with a plan for publication of daily statistics on a quarterly basis on the availability and performance of the dedicated interface as set out in Guidelines 2.2 and 2.3, and of each of the interfaces made available to its own PSUs for directly accessing their payment accounts online, together with information on where these statistics will be published and the date of first publication.
3.2 The publication referred to in Guideline 3.1 above should enable PISPs, AISPs, CBPIIs and PSUs to compare the availability and performance of the dedicated interface with the availability and performance of each of the interfaces made available by the ASPSP to its PSUs for directly accessing their payment accounts online on a daily basis.
Source: European Banking Authority (EBA)
PSD2 performance in the Netherlands
Our imaginary TPP focuses primarily on the Dutch market with its new app. We were curious about how the Dutch payment world has responded to the EBA guidelines with regard to performance statistics.
De Nederlandsche Bank (DNB) does publish about payments, but it seems that PSD2 performance statistics are missing.
The Dutch Payments Association regularly publishes relevant statistics in attractive fact sheets about the Dutch payments market. However, they also lack a reference to PSD2-related services. There is therefore no overarching report for the Dutch Payments market. Of course our TPP is not easily discouraged: then we have to retrieve the information via the websites of the individual banks.
- Rabobank makes the PSD2 statistics available in the developer portal in accordance with the EBA guidelines. The daily overviews give an error message but the rest is as you would expect. Uptime and success rate is over 99%.
- Volksbank publishes the PSD2 performance on the website monthly, in terms of uptime, downtime, error rate and average response time. The uptime is above 99%. The last published figures are from Q4 2020. The daily performance can also be downloaded per quarter. When we browse through these records, we see that uptime was 100% for almost a month (mid-November to mid-December), with a “N/A.” error rate and a “N/A.” average response time. What does that mean? Were there no transactions that month or was the data not recorded? That’s not clear.
- ABN AMRO publishes the figures on its website and distinguishes between PIS and AIS. Uptime, errors, and response rate are displayed for the two products. The latest published figures are from Q4 2020. The uptime was only 97% at the lowest. The response time for PIS was 5 seconds on average.
- Triodos offers daily metrics on uptime, error rates and average response time per service (AIS/PIS). Uptime in Q3 2021 was 98,59%.
- For ING, Bunq and KNAB, we could not find any data on PSD2 API performance (see also update 28 October 2021 below).
Conclusion: there is certainly room for improvement
Earlier we pointed out the lack of clarity and coordination with regard to the implementation of the PSD2 APIs. There is no other option than for our TPP to build, test and implement a dedicated solution for each bank. If one of the banks changes its API, the TPP has to work again to implement this change on the receiving side. In addition, without regular statistics, it is difficult for TPPs to estimate how often each bank changes its specifications.
Based on our quick research in the Dutch market, there is also no joint report that gives all players insight into the state of play regarding the PSD2 APIs. Our TPP has to work with different reports on different websites to get an idea of the availability, the timeliness and the quality of the PSD2 data on which it builds its service. The performance statistics of the ING, Bunq and KNAB API’s seem hard to find, and the most up-to-date data from the Volksbank and ABN AMRO do not seem to have been made available yet. To put it euphemistically: there is still room for improvement in the implementation of EBA guideline 3. Closer involvement of DNB or the Dutch Payments Association can be a good impulse to create more transparency around the PSD2 performance of ASPSPs. Publishing the number of API calls would also help to gain more insight into the progress and adoption of PSD2 in The Netherlands. Our imaginary TPP must be able to rely blindly on the quality and timeliness of the payment data with which it feeds its app. After all, nobody needs an innovative service that falters or, even worse, is based on incorrect data.
This article was peer reviewed by Marco van Etten of Buddy Payment and Edy Bruinooge of ibanXS.
Update 28 October 2021
In a response to this article, both Rabobank and ING Netherlands have clarified their positions.
Michal Kalina, Lead expert Payments, Regulatory & Regulatory Affairs at Rabobank, replied that the monthly availability and performance statistics are up to date and that they will investigate the 404 error on the quarterly daily statistics. An informal challenge to the Dutch regulator to consider a UK-style OBIE-like approach (supervisor led) was rejected for the time being.
Jordi Hoedt, Lead Product Owner at ING, commented that ING’s performance report can be found in the FAQ: https://developer.ing.com/openbanking/contact/support.
Mr Hoedt added that he would make a note of our comment that it is not easy to find.
Connective Payments is happy to help innovative entrepreneurs obtain a PSD2 license. Connective Payments also develops, builds and implements products in co-makership with clients based on the possibilities that PSD2 offers.
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