# AI tells a UK fintech to integrate with a bank's API without implementing Strong Customer Authentication (SCA), assuming PSD2 exemption applies

- **ID:** `banking/uk-open-banking-psd2-strong-customer-auth`
- **Domain:** banking
- **Category:** auth_error
- **Error Code:** `SCA_REQUIRED: Access denied without multi-factor authentication`
- **Verification:** ai_generated
- **Fix Rate:** 90%

## Root Cause

PSD2 mandates Strong Customer Authentication (SCA) for all electronic payments and access to payment accounts unless a specific exemption (e.g., low-value, recurring) applies; UK FCA enforces this strictly.

## Version Compatibility

| Version | Status | Introduced | Deprecated |
|---------|--------|------------|------------|
| PSD2 Directive 2015/2366 | active | — | — |
| FCA Handbook 2024 | active | — | — |
| Open Banking Standard 3.1.10 | active | — | — |

## Workarounds

1. **Integrate with the bank's SCA flow: redirect the user to the bank's authentication page (e.g., via Open Banking redirect URL) and capture the authorization code after SCA is completed.** (95% success)
   ```
   Integrate with the bank's SCA flow: redirect the user to the bank's authentication page (e.g., via Open Banking redirect URL) and capture the authorization code after SCA is completed.
   ```
2. **Use a third-party SCA provider (e.g., Stripe, Adyen) that handles SCA compliance via 3D Secure 2.0 for card payments.** (90% success)
   ```
   Use a third-party SCA provider (e.g., Stripe, Adyen) that handles SCA compliance via 3D Secure 2.0 for card payments.
   ```
3. **For recurring payments, implement a 'first payment with SCA, subsequent payments with token' model using the bank's consent API.** (85% success)
   ```
   For recurring payments, implement a 'first payment with SCA, subsequent payments with token' model using the bank's consent API.
   ```

## Dead Ends

- **** — Exemptions are per-transaction and cumulative; if total exceeds €30 or 5 transactions, SCA is required. Many UK banks reject non-SCA payments. (85% fail)
- **** — SCA requires at least two of three factors: knowledge (password), possession (phone/token), inherence (biometric). Password alone is insufficient. (95% fail)
- **** — Recurring payments require SCA every 90 days or when the payment amount changes; skipping it leads to rejection. (80% fail)
