The letter is addressed to Commission Vice-President and it is an initiative by 19 European and national ecommerce, small merchants, start-up, ICT and digital technology, payments and FinTech, cards, and leisure and travel industries. The association welcomes that the EBA acknowledged the importance of a risk-based approach through a Transaction Risk Analysis (TRA) to online merchants’ business models.
However, Ecommerce Europe stresses that the draft standards fail to address the importance of the merchant side to the application of TRA. Players across the electronic payments value-chain agree that the merchant side should be allowed to apply Transactional Risk Analysis to the benefit of increased payment security without creating unnecessary friction to the customer checkout experience.
The letter specifies that merchants and their PSPs must be given the option to use TRA, and their individual fraud rates must be taken into account; TRA must apply to the dynamic linking requirement and fraud tolerance thresholds should be simplified, based on available industry norms and applied to all transactions, with no upper transaction limit.
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