The FIDO Alliance has submitted responses and recommendations to the European Banking Authority (EBA) as part of a request the latter made for input on technical standards on strong customer authentication.In its response, FIDO details how FIDO-compliant implementations that follow security best practices can be examples for developing EBA regulations.The EBA has been tasked with developing a regulatory technical standard for strong consumer authentication for payment service providers across Europe, as required by a revised Payment Services Directive (PSD2).In the FIDO Alliance response to the EBA, the group describes how the EBA's acceptance of FIDO's public key cryptographic architecture, especially when combined with on-device biometrics, could reduce the vulnerability surface of their payment service providers – and presumably also reduce online fraud rates as a result – and accelerate overall online payment volume through reduced friction in the user experience.FIDO noted that all biometrics – behaviour-based and otherwise – are not equal.As such, “the FIDO Alliance is researching the feasibility of launching a biometric testing program to validate that biometrics proposed for use in FIDO Authenticators meet thresholds for accuracy and robustness”.FIDO also says that the independence of authentication elements is an essential question when considering strong customer authentication – particularly when all authentication factors rely upon the traditional “shared secrets” model of credentials, such as passwords and one-time passcodes.”The state-of-the art solution leverages architectures such as FIDO, where we use asymmetric cryptography for authentication, and do so in a way that is designed to address both modern security and mobility challenges, as well as consumer expectations”.