EBU Single Rulebook Q&A 10 April 2019 2019_4664 Applicability of SCA to electronically processed SEPA Direct Debits / Interpretation of EBA Q&A 2018_4359

Are mandates for direct debits which are set up without direct involvement of the payer’s PSP subject to SCA requirements? WithQ&A 2018_4359it has been clarified, that a direct debit transaction is not subject to SCA, as it is defined in the PSD2 as a transaction initiated by the payee.