Could the inclusion of a barcode image within an Advanced Electronic Signature help meet PSD2 segregation requirements?
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4 comments
Article 2.2b of the Draft RTS for SCA and CSC under PSD2 states "The channel, device or mobile application through which the information linking the transaction to a specific amount and a specific payee is displayed shall be independent or segregated from the channel, device or mobile application used for initiating the electronic payment transaction"
In the case where payments are initiated via scanning a QR code on an invoice, if the captured image that was used to successfully scan the barcode could be retained, would this provide sufficient evidence of segregation?
The bitmap image could be included within the advanced electronic signature structure. In the event of a dispute, the barcode could be rescanned to confirm the origin of the payment details.
The Quali-Sign Banking app (Android version) now includes the ability to initiate payments via scanning an invoice. Here are some screenshots and a recording. However the Android API's don't appear to provide access to the image. I have therefore posted a feature request on the Android forum.
I would be very interested in people's opinons as to whether this idea has any merit.
Regards, Michael