Crucial decision to allow a risk-based approach for electronic payments

24 February 2017

In light of yesterday’s publication of the Regulatory Technical Standards (RTS) on Strong Customer Authentication (SCA) by the European Banking Authority (EBA), Ecommerce Europe welcomes the decision to introduce transactional risk-based assessments for electronic payments up to €500.

“We welcome the EBA’s decision to take into consideration the concerns voiced by the e-commerce sector during the public consultation last year. Online merchants today have the technological means to monitor, in real time, the behavioral patterns of their customers to effectively analyze the potential risk of any particular transaction. Online merchants then take the necessary mitigating measures to prevent fraud, while the legitimate customers always remain protected. The EBA has now acknowledged the role of transactional risk-based technologies to the success of the European e-commerce industry” said Marlene ten Ham, Secretary General of Ecommerce Europe.

The final draft’s approach to introduce exemptions to Strong Customer Authentication safeguards online merchants’ business models while increasing the overall security and confidence in electronic payments and tackling online fraud. Ecommerce Europe welcomes the approach taken to allow transactional risk-based assessment up to a value of €100. Considering the fall in transactional value brought about by the growing popularity of e-commerce for smaller purchases, in many countries this covers the majority of electronic transactions.

Ecommerce Europe furthermore welcomes the decision taken, to introduce risk-based assessments for transactions between €100 and €500 based on the overall fraud levels of the payer’s Payment Service Provider’s fraud rate. We believe that this is the right direction towards ensuring that customers can be offered the most secure and convenient checkout experience, although the acceptable fraud reference rates under Article 16 should not be set too stringent and in dialogue with industry players.

Apply risk-based analysis to all electronic transactions

Considering the EBA’s introduction of risk-based analysis for transactions between low-value transactions of up to €30 and transaction up to €100, Ecommerce Europe calls on the European Commission to allow a risk-based approach for all transactions up to €100. In any case, Ecommerce Europe believes that a one-size-fits-all approach to online fraud prevention through monetary thresholds does not effectively address the difference in industries and sizes of business prone to online fraud.

In light of the significant growth of e-commerce through mobile devices, Ecommerce Europe is equally pleased to see that the European Banking Authority has forgone its previous recommendation to introduce an independence requirement between the devices, applications and software between which transactions are initiated and authentication codes are received.


About Ecommerce Europe

Ecommerce Europe is the association representing 25,000+ companies selling goods and/or services online to consumers in Europe. Founded by leading national e-commerce associations, Ecommerce Europe is the voice of the e-commerce sector in Europe. Its mission is to stimulate cross-border e-commerce through lobbying for better or desired policy, tabling the e-commerce sectors’ demands on the agenda of those designing the necessary standards and regulations, by offering a European platform bringing the European e-commerce sector and other stakeholders together, and by providing in-depth research data about European markets. Moreover, Ecommerce Europe provides more than 10,000 certified online companies across Europe with a European Trustmark label, with the aim of increasing consumers’ trust in cross-border purchases.



National associations that are members of Ecommerce Europe


Belgium Becommerce
Czech Republic APEK
Denmark FDIH
Finland Finnish Commerce Federation
Finland Internet Industry Finland
France FEVAD
Germany Händlerbund e.V.
Greece GRECA
Ireland Retail Excellence Ireland
Italy Netcomm
Luxembourg Luxembourg E-commerce Association
The Netherlands
Norway Virke eHandel
Poland e-Izba
Portugal ACEPI
Romania ARMO
Spain Adigital
Switzerland NetComm Suisse

Ecommerce Europe AISBL
Rue de Trèves 59-61, B-1040 Brussels, Belgium


Twitter: @Ecommerce_EU

Press contact Ecommerce Europe

Marlene ten Ham

Secretary General

Tel.: +32 2 502 31 34