CLAIM-2026-08-08-05

PSD2 Article 97(1) requires strong customer authentication where the payer initiates an electronic payment transaction, and Article 97(2) requires that for remote payment transactions the authentication include elements dynamically linking the transaction to a specific amount and a specific payee.

Why it matters

Dynamic linking to a specific amount and a specific payee is the precise reason a spending cap cannot stand in for authorisation, however well engineered it is.

Sources

• betterregul2026article