Responding to API errors

We advised one of the largest banks on the following project:

DEVELOPMENT OF A STRATEGY FOR DEALING WITH A MALFUNCTIONING ASPSP SPECIAL INTERFACE

• The PSD2 Directive introduced a legal framework for the provision of new payment services: the Account Information Service (AIS) and the Payment Initiation Service (PIS). Payment institutions, electronic money institutions, or banks (TPPs) may be authorized to provide AIS and PIS services.
• Each entity that maintains a payment account (ASPSP) that is available online is required to allow the AIS/PIS provider access to that account. The possibility to use the AIS/PIS service constitutes an entitlement of the payment account user. The account is typically accessed by TPP through a special interface (API) provided by the ASPSP.
• In some cases, the API interface does not work properly (creates obstacles to the provision of AIS/PIS services) – it requires the users to take redundant actions, it limits the number of accesses, or it does not allow TPP to download data (at all or completely).
• TPP has a number of private and public law powers that allow the AIS/PIS services to be provided in an uninterrupted manner.

The advisory services of DLK Legal included:

• analysis of API performance in terms of detecting malfunctions (obstacles to the provision of AIS/PIS services)
• determination of possible actions on the part of TPP aimed at facilitating smooth provision of the AIS/PIS services (private law activities – taken directly towards the ASPSP; and public law activities – taken towards public administration bodies)