Implement PSD2 RTS Article 33(6) dedicated interface fallback exemption for ASPSPs

Verified steps

1. Confirm your ASPSP has built and published a dedicated interface (API) for TPP access per Article 30 of Commission Delegated Regulation (EU) 2018/389 (RTS on SCA and CSC).
2. Apply to your national competent authority (NCA) for an exemption from the Article 33(4) contingency mechanism (fallback), citing Article 33(6); the exemption removes the obligation to maintain an adjusted customer interface as a fallback.
3. Satisfy the four conditions in Article 33(6): the dedicated interface must meet all Article 30 requirements; it must have been widely used for at least 3 months in a market trial with live TPPs; availability and performance statistics must be published monthly; and any issue causing unavailability or underperformance must be resolved within 30 minutes.
4. Follow EBA Guidelines EBA/GL/2018/07 on the conditions for the Article 33(6) exemption; the Guidelines clarify how NCAs should assess each condition and what evidence ASPSPs must provide.
5. Maintain ongoing compliance: if the dedicated interface later fails to meet availability or performance thresholds, the NCA may withdraw the exemption and require the fallback to be reinstated.
6. If the exemption is not granted or is withdrawn, implement the Article 33(4) fallback: a modified version of your customer-facing interface that TPPs can use with appropriate identification, distinct from the standard online banking journey.