As the clock counts down to when Financial Institutions (FIs) must be ready for external testing for PSD2 open banking it is interesting to see how ready, or not, all other parties are in the value chain. Most national competent authorities have nothing published about how and where they will provide updates on Third-Party Provider (TPP) registration and approvals and many still have to begin the process of even approving/registering TPPs with some EEA markets yet to even transpose the regulations to local law.

To date Konsentus is the only TPP regulatory checking service that has launched a Sandbox to support FIs building out their end to end solutions.  The EBA register, that has been announced, is not a machine readable, real-time, online database unlike the Konsentus solution.  This means FIs looking for a solution that is more than just a registry to date have limited options announced and only Konsentus with a Sandbox live.  

Given there are some 9,000+ FIs in Europe that need to comply by March 14 2019 it has to be asked how many will achieve this deadline with so few companies currently in the market offering solutions.  Whilst in the near future it is likely that there will be more entrants it does seem that this is all leaving it very late for many of the FIs to be ready by the March 14 2019 deadline.

The United Kingdom Financial Conduct Authority (FCA) though has recently re-iterated their guidance to the UK market around the importance of these dates.

ASPSPs and TPPs should be aware that: 

1. We encourage ASPSPs to provide dedicated access to TPPs using APIs. 
2. From 14 September 2019 all ASPSPs will need to comply with obligations set out in RTS Articles 
3. All ASPSPs will also need to make available technical specifications and provide support and a testing facility by 14 March 2019.

After all in the UK for instance even if they provide an API solution the whole process for an FI (AISP) to be ready for the March deadline encompasses seven key aspects:

1. API interface, live for six months prior to externally going live
2. Exemption certificate from NCA (FCA) or fallback option
3. SCA solution
4. TPP regulatory checking
5. eIDAS Seal Certificate checking if operating in Europe
6. Access Token issuance
7. Management of Consents by PSU 

It will be interesting to see outside of the Tier 1 banks how many FIs will be ready for the date and even then given how only recently the Daily Telegraph reported “Big six come under fire for slow take-up of Open Banking rules” (https://www.telegraph.co.uk/business/2018/08/19/big-six-come-fire-slow-take-up-open-banking-rules/) how quickly things will actually move.