UK Finance Revised SCA Ramp Up plan - November 2021

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UK Finance Revised
SCA Ramp Up plan
November 2021
UK SCA Ramp Up: Sprint Ramp Up targets – Q1 2022
Ensuring SCA compliance by 14th March 2022 in a controlled manner

      Overview
The SCA PMO have previously communicated the industry agreed Ramp Up plan, which was initiated in June 2021 and then reviewed and re-
communicated to industry on 17 September 2021.

• Phase 2 (Implementation of a maintenance Ramp Up) required card issuers to reach a minimum 3% Ramp Up target by 15 October 2021.
• Phase 3 (Sprint Ramp Up) will follow the same principles with revised targets

- Targets will be set for the authorisation flow rather than authentication flow

- Issuers will continue to apply the revised targets regardless of their Ramp Up method (checking non-compliant transactions or sampling transactions sent
  to authorisations)

- All monitoring processes in place will continue:
       • Issuer metrics – turnaround timelines will be accelerated
       • Scheme metrics – data supporting industry wide visibility
       • Acquirer metrics – focussed on understanding merchant readiness

- The SCA PMO will continue working with relevant members in the ecosystem to minimise the customer impact

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Revised UK Industry SCA Implementation Plan
      UK Only: 2021 - 2022 activities: Enabling a controlled roll out to minimise customer impact

        2021               2022                           Sept                      Oct                           Nov                           Dec                  Jan                           Feb                           Mar

                                                                                                                                                                                                                                            SCA
                                                                                                                                                                                                                                        Enforcement
                                         Phase 1: Participation Lock In                      Phase 2: Maintain Ramp Up and Detailed Industry Preparation                                                                               14 March 2022

                                                                                                                                                                                     Phase 3: Sprint Ramp Up

                                                                                                                                   3%

                                                           By 15th October 2021                                     15th October to 18th January 2022                              18th January 2022 – 14th March 2022

             SCA Initiatives Live                                                                                                                   SCA Ramp up
Authentication: 3DS activated (to include usage of                                           Authentication (3DS)                                                                            Authorisation
exemptions if applicable)
                                                                 Exemptions                                                                                Exemptions and correct flagging (MIT ongoing and other out of scope)
                                                                 Transaction Risk Analysis (TRA). Other exemptions could include Trusted Beneficiary and   Transaction Risk Analysis (TRA). Other exemptions include Secure Corporate Payment
Authorisation: Correct flagging and usage of                     Secure Corporate Payment                                                                  and Low Value Payment, MIT ongoing and other out of scope
exemptions
                                                                 SCA step ups                                                                              SCA soft declines
                                                                 All transactions within the scope of SCA (not using an exemption). This includes          Transactions in the SCA scope sent directly to authorisation with no exemptions flag. It
Authorisation: Soft decline recognition (if applicable)
                                                                 Merchants Initiated Transactions (MIT) set up                                             includes LV soft decline when the cumulative LV limit has been reached

                                                                                                                                                                                                                                                       3
UK SCA Ramp Up Approach: Authorisation
Ramp Up targets have been defined to mitigate the cliff edge implementation and drive merchant
readiness

 Transaction flows                          Issuer Action          Target by Mar 22   Risk*           Considerations                  Sprint Ramp Up targets are applicable
                                                                                                                                      regardless of the sampling method applied
                                                                                                                                      by Issuers:
                                         To recognise** all
                                         flagged                                                                                      1.   Checking non-compliance transactions
                                                                    1. Acquirer TRA                                                        or
                                         transactions:
                                                                      2. Up to £25                    NA – As triggered by
    Correct Flagging                     1. Acquirer TRA                               Low
                                                                                                      merchants/acquirers             2.   Sampling transactions sent to
                                         2. LV
                                                                        3. 100%
                                                                        4. 100%                                                            authorisations
                                         3. SCP
                                         4.MIT ongoing

                                         Gradual introduction
                                         of CLV – Choose 1 or
     Soft Declines*                      a combination of:
                                         • BIN by BIN                 £85 (or by 5                    NA – As triggered by
                                                                                      Medium
    Cumulative Low                       • Inflated CLV              transactions)                    merchants/acquirers
      Value (CLV)                        • Convert into TRA

      Soft Declines*                      Monthly percentage
                                          target to be
       Non-Flagged
                                          achieved by 1 or a
     In scope with no                     combination of:                                      Detailed plan provided (on following
                                                                         100%          High
                                                                                                              page)
  exemption (and issuer                   • By value
         unable to                        • By frequency
       authenticate)                      • By BIN
                                                                                                                                                                                  4
 *Risk of Transactions being declined if they fall in the target
UK SCA Ramp Up Approach: Authorisation
      Sprint Ramp Up targets are applicable regardless of the sampling method applied by Issuers

                                                               Feb – 15th
Transaction flows                Issuer Action
                                                                  Oct
                                                                                       Nov         Dec          18th Jan 22                     1st Feb 22                     15th Feb 22              1st Mar 22                  14th Mar 22

                            To recognise all
                            flagged                                                                                                     1. As per acquirer TRA
                            transactions:
    Correct                                                                                                                                 2. Up to £25
                            1. Acquirer TRA
   Flagging*                2. LV
                                                                                                                                              3. 100%
                            3. SCP                                                                                                            4. 100%
                            4.MIT ongoing

                            Gradual introduction
                            of CLV – Choose 1 or
Soft Declines**             a combination of:
                            • BIN by BIN                         As per
                                                                                                                                                        Defined by Issuer
Cumulative Low              • Inflated CLV                        BAU
  Value (CLV)               • Convert into TRA

                                                                                                                                                                           Sprint Ramp Up
 Soft Declines*              Monthly percentage
  Non-Flagged                target to be
                             achieved by 1 or a
 In scope with no            combination of:                      As per
 exemption (and
                                                                                        3%         3%                 10%                             30%                            50%                      75%                         100%
                             • By value                            BAU
 issuer unable to            • By frequency
   authenticate)             • By BIN
                                                                                                                                 SCA PMO will be monitoring data from top 10 issuers on a fortnightly basis and will adjust as required
  *Only main exemptions used commonly across the industry are listed and in the scope of UKF PMO
 **Risk of Transactions being declined if they fall in the target                                        Top 10 Issuer Transparency Table to be issued to PMO Task Force to monitor level of impact                                               5
UK SCA Ramp Up: Understanding the impact
The Issuers transparency table (Top 10 only) will be available to the PMO a week after each milestone.
Aggregated industry data will continue to be provided to members on a weekly basis

Metrics Calendar

• Top 10 issuers will provide the metrics data every two weeks as per the table below
• Process for all issuers is still under discussion

                Reporting Period (Single day)                                                                         Issuer Transparency Table
                                                                      Deadline for Reporting
                    Based on Sprint Ramp Up Target                                                                       shared with the ETF*
                      Tuesday 18th January                               Friday 21st January                              Tuesday 25th January

                      Tuesday 1st February                               Friday 4th February                               Tuesday 8th February

                     Tuesday 15th February                               Friday 18th February                            Tuesday 22nd February

                        Tuesday 1st March                                  Friday 4th March                                 Tuesday 8th March

                        Monday 14th March                                 Friday 18th March                                Tuesday 22nd March

                                                             Further reporting post enforcement TBC

  * Dates only achievable if Issuers provide returns by deadline (no PMO chasing required) and data doesn’t need PMO query or validation with Issuers

                                                                                                                                                        6
UK SCA Ramp Up Approach: Authentication
Issuers have the flexibility to define their Ramp Up pace to ensure customers, operational and systems
readiness for the SCA Authentication flows

       Transaction flows             Issuer action        Target by Mar 22      Risk*                                           Considerations

                                    Start using an
                                                                                                           An inflated TRA is expected to trigger around 2% extra challenges.
                    Issuer TRA      inflated issuer TRA      Issuer TRA up to
                                                                                 Low       Flexibility: Issuers might use other principles that allows them to prepare their customers for
                     threshold      (pre SCA                £85, £220 or £440
  SCA exemptions

                                                                                                                                    their target TRA
                                    enforcement)

                                    Issuers to start
                                    recognising
                   Acquirer TRA     acquirer TRA           Acquirer TRA up to
                    threshold                                                    Low                                  NA. As triggered by merchants/acquirers
                                    acquirers: using       £85, £220 or £440
                    (only 3DS2.2)   the TRA as per
                                    SCA guidelines

                                    Step up (i.e. OTP
                                                                                                           An inflated TRA is expected to trigger around 2% extra challenges.
                                    or other 2FA)
                    Above issuer                                                         Flexibility: Issuers might use other principles that allows them to prepare their customers for step
                                    transactions               Issuer TRA       Medium
                   TRA threshold                                                                                    ups (i.e. OTP or other 2FA) above the target TRA
                                    above inflated
                                                                                                                              Linked to Issuer TRA threshold
  SCA step ups

                                    TRA

                                    Step up all
                    e-merchant      transactions as per
                                                                 100%            Low                                  NA. As triggered by merchants/acquirers
                      request       merchant request
                                    i.e. MIT first flag

                                                                                                                                                                                                7
UK SCA Ramp Up Approach: Authentication
                 Issuers have the flexibility to define their Ramp Up pace to ensure customers, operational and
                 systems readiness for the SCA Authentication flows

     Transaction flows                 Feb - Aug               Sep                 15th Oct                 Nov                    Dec                18th Jan 22             1st Feb 22             15th Feb 22   1st Mar 22   14th Mar 22

                                                                                       Issuer flexibility in using alternative strategies to prepare their customers for their target TRA (i.e. Inflated TRA)
                 Issuer TRA             Risk based
                                                                                                                                                                (>98%)
                  threshold           authentication
SCA exemptions

                                                                                                                                       % of potential transactions impacted (for reference only)**
                                                                                                                                             Risk based authentication continues

                  Acquirer
                    TRA                                                                                                                    As per acquirer TRA
                 threshold
                 (only 3DS2.2)

                    Above                                                Issuer flexibility in using alternative strategies to prepare their customers for step ups (i.e. OTP or other 2FA) above the target TRA
                                     Risk based step
                 issuer TRA                                                                                                                                     (>98%)
                                           ups
                  threshold
SCA step ups

                                                                                                                                       % of potential transactions impacted (for reference only)**

                 e-merchant
                                                                                                                                                     100%
                   request

                        *Risk of Transactions Being Declined   ** Based on non-secured volume of transactions by band. Source: Implementation TF issuers                                                                                 8
Appendix

           9
eCommerce Journeys impacted by SCA
Overview of all SCA transaction flows impacted by the regulation. The UKF Ramp Up only will set
targets for the Authorisation flows

                                                                                                                                                            merchant/Acquirer
                                                            Transaction flows                                                 Description                                                Issuer action            Friction
                                                                                                                                                                 action

                                                                                                                •   TRA thresholds:
Issuer Ramp Up Guidance
          There are two methods for the ramp up target. Both methods look at authorisation data only
          and reach to the same volume of soft-declines
Ramp Up Method                                                                                                                                                                            SCA Compliance Ramp up                                  Outcomes                         Pros / Cons of Methods
                                                                                                                                                                                                         Approach
                                                                      (Authorisation                                                                                                                                              1,000 in-scope ecommerce transactions     ✓ Targeting specifically non-compliant
              All in-scope e-Commerce transactions

                                                                           Traffic)                                                                                                                                                                                           transactions to ensure merchants
                                                     Authentication                                                                                                                                  Compliant
                                                                       Transactions                                                                                                                                             3DS         MIT     Exemption     No flag     readiness by SCA enforcement date
                                                                       with 3DS flags                                                                                                                                           20%*       10%*       30%*         40%*     ✓ Minimising customer impact by not
                                                                                                                                                                                                                                                                              compliance checking all transactions
                                                                         Flagged
                                                                                                                                                                                                     Compliant                                                              ✓ Sending a clear signal to merchants
                                                                         correctly                                                                                                                                                                                            on importance of exemption flagging
                                                                                                                                                                                                                                            Ramp up target: 400
                                                                         MIT not                                                                                                                                 Issuers soft                                                 and readiness
 Method                                                                  flagged                                                                                                                                 decline non-
   1                                                                     correctly          Some issuers may opt to include MIT not correctly flagged as part of their sampling                                    compliant
                                                     Authorisation                      Soft Decline Targets                                                                                                     transactions                                               χ   May not include MIT transactions not
                                                       (Direct to                                                                                                                                                    as per      Soft-declines on 18 Jan @ 10%                  flagged correctly – resulting in large
                                                                                        as per issuer                                                                                                  Non-         targets:
                                                     Authorisation)
                                                                                        approach. For
                                                                                                                                                                                                                                            target: 40                          declines at enforcement date
                                                                                                                                                                                                     compliant
                                                                       Non-flagged
                                                                                        example:                                                                                                                                                                            χ   Checks by issuers that will be required
                                                                       (incorrectly                                                                                                        100%                   June: soft-
                                                                                                                                                                                75%                              decline 10%                                                    at enforcement date, would not be
                                                                         flagged)                                                                                    50%                                                                                                        tested prior to enforcement
                                                                                        •     By value                                                   30%
                                                                                                                                                                                                                    of non-
                                                                                                                                                                                                                                 SCA Soft declines as % of ramp up
                                                                                        •     By frequency                                                                                                         compliant
                                                                                                                                              10%
                                                                                                                                                                                                                 transactions               target: 10%
                                                                                        •     By BIN                               3%
                                                                                                                       Jun -15    15 Oct –   18 Jan 22   1 Feb 22   15 Feb 22 1 Mar 22   14 Mar 22
                                                                                                                         Oct     17 Jan 22

                                                                      (Authorisation                                                                                                                                              1,000 in-scope ecommerce transactions     ✓ Targeting all in-scope e-Commerce
              All in-scope e-Commerce transactions

                                                                           Traffic)                                                                                                                               Checking                                                    traffic could lead to more short term
                                                     Authentication                                                                                                                                  Compliant       SCA
                                                                       Transactions                                                                                                                                             3DS         MIT     Exemption     No flag     pain in declines (as a percentage of
                                                                       with 3DS flags                                                                                                                            compliance     20%*       10%*       30%*         40%*       sample) but will provide greater
                                                                                                                                                                                                                   on all in-
                                                                                                                                                                                                                                                                              readiness assurance to issuers as all
                                                                         Flagged                                                                                                                                   scope e-
                                                                                        Compliance Targets                                                                                           Compliant   commerce
                                                                                                                                                                                                                                                                              journeys are being checked
                                                                         correctly      as per issuer                                                                                                                                                                       ✓ At enforcement date, issuers will be
                                                                                                                                                                                                                  traffic and    Sample size on 18 Jan @10% target: 100
                                                                         MIT not        approach. For                                                                                                                soft-                                                    100% compliant
 Method                                                                  flagged        example:                                                                                           100%
                                                                                                                                                                                                                 declining if                                               ✓ Sending a clear signal to merchants
   2                                                                     correctly                                                                                                                                   non-                                         No flag     on importance of exemption flagging
                                                                                                                                                                                                                                                                   40%*
                                                     Authorisation                      •     By value                                                                          75%
                                                                                                                                                                                                                  compliant                                                   and readiness
                                                       (Direct to                       •     By frequency
                                                                                                                                                                                                       Non-       June: 10%
                                                     Authorisation)                     •     By BIN                                                                                                                of all in
                                                                                                                                                                                                                                                                            χ   May dilute message to target only
                                                                                                                                                                     50%                             compliant
                                                                       Non-flagged                                                                                                                                  scope              Soft-declines on 18 Jan: 40              non-flagged (non-compliant)
                                                                       (incorrectly                                                                      30%
                                                                                                                                                                                                                 transactions                                                   transactions.
                                                                         flagged)                                                                                                                                are checked
                                                                                                                                              10%
                                                                                                                                                                                                                       for
                                                                                                                                   3%                                                                                           SCA Soft declines as % of sample: 40%
                                                                                                                                                                                                                  compliance
                                                                                                                       Jun -15    15 Oct –   18 Jan 22   1 Feb 22   15 Feb 22 1 Mar 22   14 Mar 22
                                                                                                                         Oct     17 Jan 22
 *Proportions based on 14 – 20 June industry SCA data
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