Pursuant to Article 97 (1)(b) Directive 2015/2366/EU (PSD2), Member States shall ensure that a payment service provider applies strong customer authentication (SCA) when the payer initiates an electronic payment transaction. As stated in Q&A 2018_4031, card-based payment transactions are considered as payment transactions initiated by the payer through the payee and thus fall under Article 97(1)(b) PSD2.

The nature, electronic or not, of a given element used for authorisation, as referred to in Article 64(1) PSD2, or authentication, as defined in Article 4(29) PSD2, such as a signature, is not relevant for assessing whether or not the respective payment transaction falls under the scope of Article 97(1)(b) PSD2.

Accordingly, card-based electronic payment transactions that require the signature of the payer at the point of sale for authorisation or authentication fall under the scope of Article 97(1)(b) PSD2.

Disclaimer:

This question goes beyond matters of consistent and effective application of the regulatory framework. A Directorate General of the Commission (Directorate General for Financial Stability, Financial services and Capital Markets Union) has prepared the answer, albeit that only the Court of Justice of the European Union can provide definitive interpretations of EU legislation. This is an unofficial opinion of that Directorate General, which the European Banking Authority publishes on its behalf. The answers are not binding on the European Commission as an institution. You should be aware that the European Commission could adopt a position different from the one expressed in such Q&As, for instance in infringement proceedings or after a detailed examination of a specific case or on the basis of any new legal or factual elements that may have been brought to its attention.