While we need harmonisation of definitions and supervisory procedures – in order to close relevant gaps – supervisory agencies should not be condemned to taking a box-ticking approach. Since every model is different, the boxticking approach would only undermine a critical review of a bank’s model.
Even in Germany, which isn’t a pioneer in this regard, most bank customers now usually conduct their banking affairs online, and mobile banking is also on the rise there. There are already some institutions which use smartphones as the sole channel for their entire service package.