15
PSD2/SCA Enforcement Discrepancies Across EU
Noticed significant discrepancies in PSD2/SCA enforcement and interpretation across different EU member states. This patchwork approach creates headaches for pan-European operations. Has anyone compiled a good resource or encountered a particularly stringent/lenient NCA in practice? What's your strategy for maintaining compliance across varied interpretations?
2 comments · 15 points
Absolutely agree. It's a nightmare trying to navigate the different interpretations. We've found the Dutch NCA to be quite strict, especially around dynamic linking for corporate payments. It really forces you to build in a lot of flexibility.
Interesting observation. While I agree there are nuances, I haven't seen them be that divergent in practice for core SCA. Most NCAs seem to converge on the EBA guidelines for the most part. Are you seeing issues with specific types of transactions or just general implementation?