Strong Authentication for e-Banking: A Survey on European Regulations
and Implementations
Federico Sinigaglia
1,2
, Roberto Carbone
1
and Gabriele Costa
2
1
Security & Trust Unit, FBK-Irst, Trento, Italy
2
DIBRIS, University of Genova, Genova, Italy
Keywords:
Strong Authentication, e-Banking, Internet Payments, Mobile Payments.
Abstract:
The modern, smart society needs a reliable and trustworthy access to the internet of services. Strong authenti-
cation mechanisms promise to rise the bar of security and they are polarizing the attention of both institutional
and industrial stakeholders. In this survey, we take stock of the strong authentication mechanisms used by
e-Banking services in terms of regulations and implementations. To this aim, we reviewed the EU regulations
and their evolution in the last decade and we analyzed the strong authentication mechanisms implemented by
26 major EU and non-EU banks.
1 INTRODUCTION
In the modern society, the citizens rely on their dig-
ital identity to interact with many critical services.
Among them, e-banking, e-health and e-voting are
just few examples. Clearly, these services must pre-
vent illegal accesses that might have dramatic effects.
Strong authentication (SA) mechanisms aim at
preventing unauthorized users from logging in a sys-
tem. In particular, SA mechanisms extend traditional
authentication ones in order to guarantee a higher
level of security, e.g., through the adoption of multi-
ple authentication factors. Moreover, due to the social
implications, one would expect that the adequate lev-
els of security are stated by the national authorities.
Due to the enormous interest toward SA, many
initiatives flourished in the last years. As a conse-
quence, there has been a rapid development of SA and
its exploitation in many application scenarios. Unfor-
tunately, this generated a scattered landscape where
many proprietary, scarcely documented implementa-
tions exist. Concurrently and perhaps consequently,
the national and international stakeholders did not re-
lease precise regulations and propositions on how SA
must be achieved. The result is a lack of parameters
for classifying, comparing and evaluating the existing
SA solutions in terms of security.
The goal of this paper is to provide a general
overview of the state of the art of SA. We aim at
identifying common factors that can lead to a clas-
sification of the SA mechanisms. To do that, we
consider two perspectives, i.e. regulations and imple-
mentations. In the last years, the lawmakers faced
the problem of characterizing the SA so to estab-
lish the acceptable level of security. Clearly, the ser-
vice providers have to comply with laws and direc-
tives. However, they can achieve that in many differ-
ent ways.
In this paper we focus on the following aspects.
1. EU regulations. Among the involved stakehold-
ers, EU is certainly a very active one and its laws
about SA are constantly evolving.
2. Mobility. Smartphones and tablets play several
roles in SA, including: client application (via web
browsers or mobile apps), secure hardware (e.g.,
relying on the SIM card) or second channel end-
point (e.g., for SMS or voice calls).
3. E-Banking. Banks are strongly motivated in im-
plementing SA mechanisms as part of their online
services.
Related Work. Although SA mechanisms are re-
ceiving attention from both the academia and the in-
dustry, at the best of our knowledge, no authors car-
ried out a systematic review of the existing implemen-
tations.
In (Haupert and Müller, 2016), the authors clas-
sify the SA mechanisms used by four German banks.
In particular, they focus on SA implementations based
on mobile apps. Our paper follows a similar line, but
with a new classification approach and by extending
it to banks of different countries.
480
Sinigaglia, F., Carbone, R. and Costa, G.
Strong Authentication for e-Banking: A Survey on European Regulations and Implementations.
DOI: 10.5220/0006438504800485
In Proceedings of the 14th International Joint Conference on e-Business and Telecommunications (ICETE 2017) - Volume 4: SECRYPT, pages 480-485
ISBN: 978-989-758-259-2
Copyright © 2017 by SCITEPRESS Science and Technology Publications, Lda. All rights reserved
Many authors focus on the problem of defining SA
protocols and verifying their security properties. For
instance, in (DeFigueiredo, 2011) the authors carry
out a security evaluation of two-factor authentication
on mobile devices. A similar reasoning is presented in
(Hagalisletto, 2007), but explicitly considering phish-
ing attacks. In (Armando et al., 2013), the authors use
model checking to automatically verify SA protocols.
The FIDO (Fast Identity Online) Alliance (FIDO,
2017) is a prominent initiative for the standardization
of the SA mechanisms. Several important stakehold-
ers, e.g., Google, Paypal and Bank of America, joined
the initiative. Interestingly, however, no EU banks
participate in the FIDO alliance.
Methodology. Our goal is to identify and discuss
the key concepts related to the SA mechanisms and
their features. To do that, we proceeded from abstract
to concrete. In particular, we started from the analysis
of EU directives and recommendations. As a matter
of fact, these documents provide the general defini-
tions and social requirements of the SA mechanisms.
Our presentation follows the temporal evolution of the
key concepts appearing in the documentation.
The analysis of the EU regulations allowed us to
analyze the actual SA implementations and critically
discuss their features against the directives. Thus, we
carried out a systematic review of the SA implemen-
tations used by 26 important international banks cho-
sen among the world top 100 in terms of asset (Rel-
banks, 2016). Banks were selected by considering
their (i) turnover, (ii) number of customers and (iii)
geographical distribution. In particular, we privileged
EU banks (17 out of 26) in order to understand how
they met the EU directives. For each of these banks
we parsed the available documentation referring to the
SA mechanisms, e.g., used for online payments. Such
a documentation included specifications, handbooks
and guidelines. The full list of considered documents
is available at https://sites.google.com/fbk.eu/strong-
auth-banks-survey/.
This paper is structured as follows. In Section 2,
we discuss the main EU regulations related to SA and
online payments. In Section 3, we present the data
collected about the implementations of SA mecha-
nisms. In Sections 4, we provide an overview of the
lesson learned. Section 5 concludes the paper.
2 EU REGULATIONS
In this section we present the history and evolution of
the EU directives and recommendations referring to
SA and related topics, e.g., online payments.
Payment Services Directives in the European
Community (PSD). PSD (EBA, 2007) was pub-
lished by the European Central Bank (ECB) in 2007,
with the aim of creating the basis for a unique area of
payment in the whole EU (the so-called Single Euro
Payments Area). Among those definitions, the PSD
presented the first proposal for EU rules concerning
the Payment Services which are defined as business
activities that allow people
(D1 PS) to deposit or withdraw cash on or
from a payment account, as well as the opera-
tion of that account; execute payment transactions
(e.g., standing orders, direct debits, etc.) both
on payment accounts or by electronic means; is-
sue and/or receive payment instructions; execute
money remittance [. . . ].
Noticeably, no distinction between traditional
payments (e.g., through a point of sale) and online
payments (i.e. only using the internet) is provided.
Recommendations for the Security of Internet
Payments (RSIP). RSIP (ECB, 2013a) was re-
leased in 2013 and officially became law in 2015. In-
terestingly, it was the first document with a clear def-
inition of Internet Payments (IPs). Indeed, they are
defined as
(D2 IP) the execution of card payments on the
internet, including virtual card payments, the exe-
cution of credit transfers (CTs) on the internet, the
issuance and amendment of direct debit electronic
mandates and the transfers of electronic money
between two e-money accounts via the internet.
The document also states that IPs should be pro-
tected through a mechanism of Strong Customer Au-
thentication (i.e. SA applied to banking customers).
In this context, SA is defined as
(D3 SA) a procedure based on the use of two
or more of the following elements—categorised
as knowledge, ownership and inherence: i) some-
thing only the user knows, e.g., static password,
code, personal identification number; ii) some-
thing only the user possesses, e.g., token, smart
card, mobile phone; iii) something the user is, e.g.
biometric characteristic, such as a fingerprint. In
addition, the elements selected must be mutually
independent [. . . ].
It is worth noticing that this definition explicitly
defines the three types of elements (hereafter Authen-
tication Elements, AEs in short) that one can adopt to
achieve SA. In addition, the definition states that the
adopted AEs must be mutually independent, i.e. two
AEs cannot be compromised by a single action.
Strong Authentication for e-Banking: A Survey on European Regulations and Implementations
481
According to RSIP, customers can access the PS
after a registration procedure called enrolment. A suc-
cessful enrolment leads to the activation of the AEs
(used to grant SA in the IP). This phase is called pro-
visioning. About them, the document says that the
Payment Services providers
(D4 P) should ensure that customer enrolment
for and the initial provision of the authentication
tools required to use the internet payment service
and/or the delivery of payment-related software to
customers is carried out in a secure manner.
Although generic, this is the first official statement
about the enrolment and provisioning phases and their
roles in the SA.
Recommendations for the Security of Mobile
Payments (RSMP). A similar approach was used
for RSMP (ECB, 2013b) released in the end of 2013.
Briefly, RSMP applies the concepts of RSIP to the
context of IPs involving mobile technologies. More
precisely, Mobile Payments (MPs) are described as
(D5 – MP) payments for which the payments data
and the payment instruction are transmitted and/or
confirmed via mobile communication and data
transmission technology through a mobile device
between the customer and his/her payment service
provider in the course of an online or offline pur-
chase of services, digital or physical goods.
Moreover, RSMP extends the definitions and re-
quirements already proposed in RSIP by considering
the specific aspects related to the mobile technolo-
gies. In particular, mobile enrolment and mobile pro-
visioning are defined and new constraints are added
about the distribution of mobile software through re-
liable/trusted channels/vendors.
Payment Services Directives in the Internal
Market (PSD2). In 2015, the ECB released
PSD2 (EBA, 2015). PSD2 refines the definitions of
PSD by introducing some concepts presented in RSIP
and RSMP. To do that, PSD2 combines the two no-
tions of IP and MP in a single one: remote payment
transaction. Moreover, PSD2 is the first directive that
states where SA must be employed, i.e. when the user
(i) accesses its account online, (ii) initiates an elec-
tronic remote payment transaction and (iii) carries out
any risky action through a remote channel.
Regulatory Technical Standards (RTS). Together
with the PSD2, the ECB released RTS (EBA, 2016),
with the purpose to map the abstract indications of
PSD2 into concrete technical solutions. For instance,
Table 1: Key concepts in EU regulation.
Definition
Application
Exemption
Internet
Mobile
Definition
Independence
Features
Provisioning
Enrolment
Source Year SA Pay AE Phases
PSD 2007
RSIP 2013 Î
RSMP 2013 Î
PSD2 2015 Î Î
RTS 2015 Î Î Î
a list of key features is provided for the precise char-
acterization of the features of the AEs. Furthermore,
the independence of the elements is specifically tar-
geted, requiring dedicated measures in the case that
the SA or part of it is executed through multi-purpose
devices (e.g., mobile phones and tablets). Regard-
ing the AEs provision, moreover, the RTS refers to
the contributions given in RSMP, losing the specifi-
cation of possible distribution channels but introduc-
ing new requirements regarding the elements activa-
tion (acknowledging the risks of remote distribution).
Finally, the concept of Exemption is introduced, pre-
senting some low-risk situations in which the usage
of SA mechanisms may be avoided.
2.1 Considerations
Some facts arise from the comparison of the docu-
mentation mentioned above.
SA. The notion of SA evolved over time and new con-
cepts were defined. As a matter of fact, PSD2 also in-
troduced a precise description of the cases where SA
must be applied. Moreover, in RTS some exemption
cases were introduced.
Pay. As a refinement to RSIP, in RSMP IPs and MPs
have a precise and distinct characterization. Such dis-
tinction disappears in PSD2 and RTS where the IPs
and MPs are combined under the same term, i.e. re-
mote payment transaction.
AE. The definition of AEs also evolved over time. In
particular, more attention was dedicated to the defini-
tion of independence and the identification of desired
features. These aspects have a crucial role for estab-
lishing reliable criteria for the evaluation of the AEs.
Phases. A rather precise definition of the provi-
sioning and enrolment phases is present in RSIP and
RSMP. Surprisingly enough, they do not appear in the
official directives (PSD and PSD2). However, a tech-
nical description is provided in the RTS.
Table 1 summarizes how the regulations deal with the
key concepts relevant for SA. For the sake of presen-
SECRYPT 2017 - 14th International Conference on Security and Cryptography
482
tation, we use , Î, and – when a concept is clearly,
partially (e.g., contextually to another definition or
without a dedicated statement), and not defined in the
document, respectively.
3 SA IMPLEMENTATIONS
We analyzed the SA mechanisms adopted by 26 banks
for their online payment services. Table 2 summarizes
the collected information (EU banks only).
1
Each row
describes the relevant aspects of the SA implemen-
tation of the corresponding bank. For instance, the
first row refers to Deutsche Bank from DE: the bank
offers four distinct AEs (col. AE); each AE is provi-
sioned in a different way (and the provisioning of
depends on P ); four different IP procedures are sup-
ported (one for each AE), aiming at providing the user
with an OTP that she can use to confirm the operation
on the web browser; two MP procedures are in place:
P and cannot be used for the MPs (the symbol
means that the corresponding AE is not involved in
any authentication procedure)
2
while the process for
¬ changes by replacing otp
h
with otp
i
. The mean-
ing of each column and the corresponding notation is
detailed below.
3.1 Authentication Elements (AE)
Below we list the AE used by the selected banks.
Among them, we do not include access credentials,
e.g., username & password, as they are common to
every service. Instead, we focus on AEs that are
requested at each payment. For each AE, in brack-
ets we report the category (Ownership, Knowledge or
Inherence), following the definition D3 in Section 2.
# Smart Card (O). It is a magnetic card, with a
unique card code, that also embeds high-security elec-
tronic circuits, dedicated to cryptographic operations.
Since the Smart card is usually given when the cus-
tomer applies for the bank account and it is always
used in combination with other AEs, we omit it in the
AE and P columns of Table 2. It is only considered in
the IP and MP columns.
P HW OTP Generator (O). It is a hardware de-
voted to the generation of one-time passwords (OTP).
The features of these AEs may vary significantly. For
instance, a simple generator provides the user with
an OTP when she performs a single operation (e.g.,
pressing a button, inserting a PIN). On the other hand,
1
The full table and data are available at the companion web-
site.
2
Banque Populaire and Credit Agricole allow to execute
MPs without SA (only basic authentication is required).
Table 2: SA implementations (EU banks).
Bank name C AE P IP MP
Deutsche B. DE
P
¬
/8
r P
r
opid
o
P op ? otp
h
(x,y) otp
h
otp
m
otp
h
opid
o
¬ op ? otp
h
(x,y) otp
h
opid
i
¬ op ? otp
i
Sparkasse DE
P
¬
r
opid
o
P # op ? otp
h
otp
m
otp
h
opid
n
¬
op ? otp
h
opid
o
P # op ? otp
h
opid
i
¬
op ? otp
i
Commerzbank DE
P
¬
r 8
r
r 8
r
opid
o
P op ? otp
h
(x,y) otp
h
otp
m
otp
h
opid
n
¬
op ? otp
h
opid
o
P op ? otp
h
opid
i
¬
op ? otp
i
Barclays UK
P
¬
¬
r P /
r P /
P #
otp
h
¬
otp
h
¬ otp
h
opid
i
¬
# otp
i
opid
i
¬ # otp
i
RBS UK
P
¬
r
r 8
r
opid
h
P #
otp
h
opid
i
¬
otp
i
LLoyds Bank UK
opid
h
HSBC UK
P
¬
8 r
r
P
otp
h
¬
otp
h
opid
i
¬
op ? otp
i
Banca Intesa IT
P
¬
¬
r P
r P
P otp
h
opid
n
¬
op ? otp
n
opid
n
¬ op ? otp
n
P otp
h
opid
i
¬
op ? otp
i
opid
i
¬ op ? otp
i
CheBanca IT
¬
¹
r
r
otp
m
otp
h
¬
otp
h
opid
i
¬
op ? otp
i
Unicredit IT
P
¬
¬
r [
r [
P otp
h
(x,y) otp
h
opid
h
¬
op ? otp
h
opid
h
¬ op ? otp
h
opid
i
¬
op ? otp
i
opid
i
¬ op ? otp
i
BNP Paribas FR
¬
r
r
otp
m
otp
h
opid
n
¬
op ? otp
n
otp
m
otp
i
opid
i
¬
otp
i
Credit Agricole FR
/r
otp
m
otp
h
Societe Generale FR
¬
/r
r
otp
m
otp
h
opid
n
¬
op ? otp
n
opid
i
¬
op ? otp
i
B. Populaire FR
P
P #
otp
h
otp
m
otp
h
B. Santander ES
otp
m
otp
h
otp
m
otp
i
BBVA ES /
otp
m
otp
h
otp
m
otp
i
CaixaBanca ES
(x,y) otp
h
otp
m
otp
i
with a card reader, the user has to employ an associ-
ated smart card in order to obtain the OTP.
¬ SW OTP Generator (O). An OTP can also be
software-generated. For instance, some banks dis-
tribute a mobile app. The apps are dedicated to the
OTP generation or include it as one of their function-
alities. SW OTP generation is the counterpart of HW
OTP generation and works analogously.
Access Matrix (O). It consists of a matrix where
every cell contains a number. To generate an OTP, the
user is requested to provide the sequence of numbers
appearing in the given cells.
SIM Card (O). Using a SIM card, the remote ser-
vice sends the OTP directly to the phone number as-
sociated to the user, e.g., via SMS or voice call.
Extra Knowledge (K). A piece of information
shared between the user and the bank. Commonly
a PIN number, pass-phrase or a secret question that
the user has to recall (sometimes referred to as mem-
orable information). The extra knowledge can be de-
cided by either the user or the bank.
Strong Authentication for e-Banking: A Survey on European Regulations and Implementations
483
User Fingerprint (I). The mobile device of the
user embeds a reader that recognizes her fingerprint.
It is worth noticing that some ownership AEs are
combined with a dedicated knowledge or inherence
AE, e.g., a credit card may have a PIN or an app may
request the user fingerprint. To denote these AEs, we
add an extra annotation like in #
and ¬ .
3.2 AE Provisioning (P)
The provisioning is the process used to issue and ac-
tivate an AE to the user (see D4). We distinguish
among the following actions.
The user goes to a local branch. For instance,
a user can retrieve an object (e.g., an HW OTP
generator P ), establish a shared extra knowledge
() or register her SIM card phone number ( ).
r The user interacts with the web portal of the bank.
For instance, the user can download/activate a SW
OTP generator (¬), an access matrix () or ex-
change an extra knowledge () with the bank.
¹ The user has a phone call with a remote service.
Often it is used to activate an AE such as a credit
card (#) or a SIM card ( ).
[ The user sends/receives an email. For instance,
the user can receive instructions or secret codes
necessary to unlock/activate/register an AE.
8 The bank and the user communicate via snail mail
or courier. This channel can be used for the same
purposes of [. Also, is often used to deliver an
AE, e.g., an HW OTP generator ( P ).
The user operates via an automated teller machine
(ATM). For instance, ATM can be used to activate
a SIM card ( ) or an SW OTP generator ( ¬).
Similar to [, but carried out through the SMS ser-
vice of the user’s mobile telco provider.
To denote a provisioning procedure we use a se-
quence of the symbols given above. The meaning is
that the user has to perform the corresponding oper-
ations in sequence, e.g., r means that the user in-
teracts with a web portal and then sends/receives one
or more SMS. Notice that we also use AE symbols
when the provisioning procedure requests them. Fi-
nally, when the flow admits two independent alterna-
tives we use /. For instance r
P/ denotes that the
provisioning can be carried out either online ( r) or
in a local branch (). In the first case, the AE P is
also necessary.
Table 3: List of data objects.
Description R/W agent
opid
h
human-readable opid human
opid
o
scannable opid camera
opid
n
network notified opid app
opid
i
interprocess notified opid app
otp
h
human-readable otp human
otp
i
interprocess notified otp app
otp
n
network notified opt app
otp
m
otp on sms gsm
(x,y) coordinates human
3.3 Remote Payment Transactions (IP,
MP)
We characterize a payment procedure through the se-
quence of AE (see above) that it involves and their
input/output data. In particular, we use the following
notation.
A plain text denotes a data object. Also, each data
object is transmitted through a specific channel.
Table 3 shows the list of the data objects appearing
in the online payment procedures.
Icons denote the AEs, e.g., for an access ma-
trix. When two or more AEs are combined we
put them in sequence, e.g., P # for a smart card
used with an HW OTP generator (card reader).
is used for input/output and concatenation. For
example, we write (x,y) otp
h
to represent
that some coordinates are given as the input of an
access matrix () to obtain an OTP that the user
reads (otp
h
). Notice that the interpretation of the
symbol may vary in accordance with the pay-
ment context (see at the end of this Section).
op ? indicates that the user is prompted with the
details of the ongoing operation and she must au-
thorize the continuation of the procedure.
Although the most recent EU regulation (PSD2)
does not distinguish between them, here we treat IP
and MP separately (as in RSIP and RSMP). The main
motivation is that we expect the collected data to sup-
port the security analysis of the SA implementations.
For instance, IP and MP admit different attacker mod-
els, e.g., man-in-the-browser vs. man-in-the-mobile
(see (Haupert and Müller, 2016)). These differences
are discussed and motivated in Section 4. As a con-
sequence of this distinction, the reader must take into
account that IPs and MPs provide a context for the
notation introduced above. For instance, the expres-
sion opid
h
P otp
h
has two interpretations: (IP)
the user receives an opid from the browser, uses it
SECRYPT 2017 - 14th International Conference on Security and Cryptography
484
with an HW OTP generator and she submits the OTP
to the browser; and, (MP) the user gets the opid from
(and puts the OTP in) the mobile app.
4 LESSON LEARNED
Key Findings. We put forward some observations
based on the results of the survey.
1. Ownership AEs are predominant and many banks
use more than one of them. Also knowledge AEs are
common, while inherence AEs are scarcely adopted.
2. Banks support multiple IP and MP procedures (on
the average 2.3 IP and 1.6 MP) and AEs (average 2.5).
This clearly enlarges the attack surface of the systems.
3. Among the considered SA implementations 21/26
leverage ¬ or for executing an IP. Among these, 7
do not provide alternatives, i.e. the user has to rely on
her mobile device.
4. is adopted by 5 banks for both IP and MP. Ac-
cording to (Haupert and Müller, 2016), this could af-
fect the independence of the AEs, as both ¬ and
can reside on the same device.
Discussion. Beyond the previous observations, we
put forward some general considerations.
Regulation is vague. As shown in Section 2, the law-
makers acknowledged the peculiarities of IP and MP
in wavering manner. Moreover, at the current stage
the features of the AEs have not been rigorously de-
fined. Hence, a large variety of AEs exists and a com-
parison in terms of security features is extremely hard.
Mobile is a bottleneck. In case of MPs that only in-
clude operations on a mobile device, the AEs inde-
pendence is at risk. As a matter of fact, the mobile
device turns out to be a single point of failure and,
thus, a privileged target for the attackers (Haupert and
Müller, 2016).
Diversity of the implementations. Most banks imple-
ment their own SA mechanism. The reason is prob-
ably that they follow their specific interest toward
legacy problems, usability, flavor of customers, etc.
However, having many implementations increases the
risk that some of them are flawed or incorrect.
Understanding of the user. Faced with many alterna-
tives, often the user does not understand the impor-
tance of the operations and which SA mechanisms
better fit with her necessities. Thus, the customers
might tend to focus on the usability aspects, which
they perceive as an added value. Clearly this could
promote risky habits, e.g., storing knowledge AEs in
an unsafe way.
5 CONCLUSION
We presented a survey taking into account both EU
regulations and implementations of SA mechanisms
for e-Banking services. We believe that the selected
parameters and the results of our survey are a valuable
starting point for a comparison and pave the way for
an evaluation of the security of different SA mecha-
nisms. As part of the future work, we plan to extend
our survey by defining a classification method for cat-
egorizing the security risks affecting SA implementa-
tions. Such a mechanism should also be aware of the
specific features of each AE and the relevant attacker
models.
ACKNOWLEDGEMENTS
The present work has been partially supported by
CINI Cybersecurity National Laboratory within the
project FilieraSicura: Securing the Supply Chain of
Domestic Critical Infrastructures from Cyber Attacks
(www.filierasicura.it) funded by CISCO Systems Inc.
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