PSD2 Obstacles

Public registry of PSD2 obstacles

The table below contains identified PSD2 obstacles arising out of ASPSP implementation of PSD2 account access requirements. These obstacles existed at the time of compilation of this list over 2021-2022.

What is the problem we are trying to solve?

With more than 3 years of PSD2 API implementation we still aren't seeing a successful and coherent implementation of PSD2 that Fintechs can succeed on. This public registry shall help lead to the fruition and successful implementation of PSD2 by disclosing obstacles, and thus putting additional pressure for the much needed removal of these obstacles. 

This public disclosure of obstacles has the following benefits:

Disclaimer: ETPPA does not accept any liability from any inaccuracies or improper listing of obstacles. All obstacles listed were unresolved at the time of entry into the registry. ETPPA welcomes any contact regarding a particular obstacle in case of proof of obstacle resolution. In case you wish to request more information on any of the listed obstacles or in case an ASPSP wishes to inform ETPPA of any inaccuracies due to identified obstacles being resolved, please send a mail to with the obstacle ID number, member state and bank alias in the email subject. Please also include your name and organisation.  

Obstacles can be downloaded in PDF format here.

PSD2 Obstacles Published 2022 11 03 - PSD2 Obstacles.pdf