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The directive is intended to drive greater choice and security for consumers, and one of its key elements is Strong Customer Authentication (SCA). This is designed to reduce fraud and ensure consumer credentials are properly validated for all electronic payments. While the EBA’s latest opinion paper does grant national competent authorities some flexibility in applying the new rules to PSPs, effectively opening a welcome window for a deadline extension, the entire industry remains focused on correct interpretation of the complex legislation and meeting the September 14 deadline.

Strong Customer Authentication obliges card issuers will be obliged to perform an SCA check for every electronic payment transaction unless it qualifies for an exemption. This SCA check is essentially a two-factor authentication process – and it has important implications for merchants.

Out of merchant hands?

Merchants cannot fend off the SCA requirement for card payments – because their bank will no longer have a free choice on whether or not to perform SCA. In cases where the issuer is required to perform SCA, the merchant must also support it, or the issuer is likely to soft decline the authorization request.

There are some ways around the process, but these are not steps that merchants themselves can take. A cardholder can apply to have a particular merchant ‘whitelisted’ with their card issuer, but the decision will ultimately be the bank’s. Similarly, issuers and acquirers may exempt low-risk transactions under €500 provided they maintain sufficiently low levels of fraud. To do this, transaction risk analysis (TRA) has to be in place to prove that fraud is being kept below set thresholds. It makes sense that issuers will look to apply the TRA exemption as much as possible to reduce friction in the checkout process, but this remains outside the merchant’s direct control.

Merchants must also be wary of fraud liability risks. For transactions that are subject to SCA, liability rests with the issuer or acquirer (whoever applies the exemption) if the transaction turns out to be fraudulent. But, in some circumstances, where an exemption is applied, acquirers will likely pass liability back to the merchant.

Finally, although PSD2 requires that fraud rates are assessed at the issuer or acquirer level, it is still important for each merchant’s fraud rate to remain low, to avoid pushing the issuer or acquirer’s overall fraud rate over the threshold. If that happens, every eCommerce transaction, regardless of amount and regardless of individual merchant performance, will have SCA applied and exemptions will not be allowed. This means issuers and acquirers are likely to come down hard on individual merchants who allow their fraud rates to rise.

Merchants can still protect their interests

Merchants need to continue to manage fraud to secure SCA exemptions and deliver a fast, simple payments experience to loyal customers. By keeping a firm grasp on fraud rates and knowing when and how to request exemptions, merchants can protect their businesses and help to ensure that the new regulations are a benefit, and not an impediment, to genuine consumers. Here are a few guiding principles:

    1. Don’t neglect fraud screening
      Fraud screening remains vital for merchants to ‘de-risk’ transactions and protect customer relationships. Merchants understand the business and behaviors of their own customers better than anyone else – arguably, they are best placed to protect those customers from fraud. It isn’t enough to rely on issuers and acquirers to carry out risk analysis, any more than it is enough to rely on 3D Secure when authenticated fraud remains an issue for many merchants.
    2. Cover off the contingencies
      Achieving low fraud rates can help merchants avoid scheme fines and build good relationships with acquirers. Merchants should actively engage with their acquirers to discuss their authentication strategy, pushing for the exemptions they want and ensuring there is a back-up plan or fallback position if customer authentication fails. There may be situations in which a merchant does not wish an available exemption to be applied, so the exemption strategy should be jointly agreed between the merchant and acquirer.
    3. Establish acquirer flexibility
      Finally, some merchants may wish to negotiate with acquirers to implement transaction risk analysis exemptions for themselves and – in the future – we could see savvy merchants ‘cherry picking’ the acquirers that offer the best conversion, SCA strategies and commercials. The ability to easily switch acquirers, route transactions to acquirers with the best fraud levels, and negotiate acquiring services (and prices) will be increasingly valuable in a PSD2 world.

If you’re a merchant and would like to discuss the implications of PSD2 and SCA on your business, you can download a copy of our guide, or speak to one of our expert analysts for more advice:

Director, Fraud Product Management

Currently Director of Fraud Product Management at ACI Worldwide, Jackie has more than 27 years’ experience within financial crime. She joined Retail Decisions (ReD) in late 2011, prior to its acquisition by ACI in 2014, as Head of International Products, ensuring ReD’s fraud and payment solutions enabled revenue growth and reduced losses for customers in all markets.  She assumed responsibility for ReD’s product portfolio and roadmap in 2013 and led a global team of product experts focused on the further development of ReD’s market-leading fraud and payment solutions. Before joining ReD, Jackie worked at Actimize, setting the vision and leading the development of financial crime products for the company. She was previously Director of Fraud for EMEA at First Data, and EVP, Head of Global Fraud Management at Citigroup.