7.3 Impacts for the Payment Service Providers (PSP)
E-merchants’ PSPs must implement the 3DS v2. and 3DS v3.x servers.
In particular, version 3DS 2.2 is required to collect all the required shopping cart information (by the merchants) and allow their clients (the merchants) to benefit from the exemptions and notably from the TRA exemption.
This exemption will normally be accepted unless there is a suspicion of fraud. The PSPs must be able to monitor fraud for the merchants they work with.
Depending on the cases, the merchants (mainly the larger ones) performs the risk analysis themselves and transmits all required data in 3DS. Otherwise, and this is generally the case, they delegate the risk analysis to their PSPs. The payment schemes can also provide guidance as they monitor the fraud themselves (CB, Visa, Mastercard).
7.4 Impacts for the acquirers
Acquirers are not in the 3DS process. However, they do have a role to play:
- in the transmission of authorisations, especially in exemption cases without 3DS (i.e. without SCA)
- in the trust that issuers have in the acquirers (through their fraud rate).
Thereby, fraud management is of particular importance to acquirers. Indeed, their online payments fraud rate will influence the threshold for triggering the SCA challenge and therefore the threshold for an acquirer exemption request.
The fraud rate could become a competitive advantage for acquirers. This could impact contractual discussions between acquirers and e-merchants.
7.5 Impacts for the issuers
Issuers are the most impacted actors in the frame of the SCA implementation.
Responsibility
Issuers are responsible as soon as strong authentication is activated. In other words, they are responsible if the 3DS process is activated and if they refuse the frictionless request in the frame of an exemption.
SMS OTP
The SMS OTP can still be used as a strong authentication mean under certain conditions.
Nevertheless, as the OTP is not encrypted in the SMS, it can be intercepted and therefore presents a risk. Also, the SMS OTP is not considered as a knowledge factor. It can complicate the customer journey and also generates additional costs.
Reinforced SMS OTP with a password is a compliant SCA authentication mean, that allows issuers to continue working with SMS OTP while pairing it with the homebanking password for example.
However, it generates costs related to SMS sending, and is not a user-friendly authentication mean, as the cardholders need to input two values while authentication, one after the other
Customer journey and change management
More generally, issuers need to ensure the transition from SMS authentication to authentication via their banking applications installed on their cardholders’ smartphones. This includes the implementation of the appropriate methods and mechanisms to make it work, and also the support of their own clients (the cardholders) in the process of understanding, accepting and buying in to those new authentication means.
A major change is that authentication via banking applications implies an enrolment from the cardholders, prior to any strong authentication: enrolment of the password (knowledge factor), enrolment of biometrics prints (inherence factor), enrolment of the device (possession factor), depending on the method. This should take place prior to any payment, for the cardholder to be able to use the method when performing a transaction.
From the issuers perspective, it means:
- Communicating towards their cardholders to make them understand how news authentication means work, and what is expected from them at enrolment and at authentication
- Reassuring them about the changes induced by those new methods
- Informing them about the new kinds of fraud risks that come along new authentication means
IT investments related to the management of new authentication methods
Obviously, all those changes come at a price for the issuers, which must meet strategic choices about how to manage new authentication means. They can either reinforce existing methods (implementing reinforced OTP SMS for instance, and develop the necessary tools to manage it, like a password enrolment portal), or they can implement new methods. When doing so, issuers need to decide whether they manage the solution themselves or delegate it to a third party. For example, implementing an authentication SDK in their mobile application, or use a full and ready-to-use external authentication solution.
Exceptions
Issuers need to rethink the customer journey during a strong authentication process to make sure they cover all use cases, regardless of the channel, all this by offering the most fluid and consistent path.
They also need to take into account all the "marginal" uses cases, if they want to make sure all their clients are able to authenticate strongly, whatever the situation they are in: customers who do not own a mobile, customers who do not have installed the banking application, customers who would not have a network coverage for the smartphone during an authentication request, etc.
Security
Issuers are responsible of the security (integrity and authenticity) of the authentication factors of their cardholders. This can have major impacts in terms of security choices, with significant consequences in terms of costs. Issuers will also tend to decline a transaction if the smartphone OS (Operating System) is not up to date, as this information goes in their scoring process before deciding whether or not a authentication should be challenged or declined. This example shows again the importance of appropriate communication and change management from the issuers towards their customers, the cardholders.
As an example – If the smartphone is used as a possession factor, issuers must ensure the security of the authentication process on a device they don’t master the security of. A smartphone whose operating system (iOS for Apple and Android for Google) was not updated by the phone user or which is no longer maintained by the manufacturer can present security flaws. These flaws can be exploited by hackers in order to implant malware and therefore access sensitive information and take control of the smartphone.
Issuers must ensure they put in place:
A secure environment for authentication execution
It is the environment in which the authentication process takes place (See 6). This environment integrates and protects the authentication process, and allows the issuer to free himself from the Operating System of the cardholder smartphone.
Dynamic link
During an online payment with a card, PSD2 RTS requires that the SCA process proposed by the issuer makes a dynamic link between the transaction, its amount, and the name of the merchant (or even the merchant’s payment provider), and that this information be protected throughout the entire authentication process. This ensures that the cardholder is validating the appropriate transaction. Otherwise, a user could successfully authenticate during a payment, but with a "fake" validation screen that would not be the right one, because it would have been modified by a malware in the background, or via a window popping upfront at the time of validation.
7.6 Overview: changes brought by SCA in online payments