Insofar as the legal provisions of Delegated Regulation (EU) 2018/3893 are more general, its practical application raises many issues that require additional clarification. To this end, in 2019 4. the European Banking Authority (EBA) established a Working Group on APIs under PSD2 Within this group, representatives of the EBA, the national competent authorities, the European Commission, and the European Central Bank consult the market participants (banks, third party providers and industry organisations) and identify potential practical implementation problems and possible solutions thereof. Based on the consultations, by 31 July 2021 the EBA has published clarifications on 31 issues relating to the practical application of the requirements for APIs. With the aim of converging the supervisory practices among the Member States of the European Union, in June 2020 the EBA published its Opinion on obstacles under Article 32(3) of the regulatory technical standards on strong customer authentication and common and secure open standards of communication (EBA/OP/2020/10)5. The work on the raised issues is still going on via the Q&As published by the EBA6. The Bulgarian National Bank, in its capacity as a regulator, has active communications with the market participants with the aim of improving the functionality of the dedicated interfaces already 2/3  BIS central bankers' speeches  built by the banks in the country. The process is developing in line with the European progress and in compliance with the legal framework, the opinions and clarifications published by the EBA.
This internal consistency explains why monetary policy is the only part of the EMU framework that has clearly functioned as designed. Fiscal policies were supposed to conform to the other form of governance, where countries would decide on and execute their own budgets, but within the strict constraints of the deficit and debt limits set in the Treaty. Those limits were supposed to be policed by markets, the Commission and other Member States, but in practice the incentives of the latter to enforce the rules were weak. This meant that de facto rules could be applied with discretion, while Member States themselves decided on how to exercise that discretion – in other words, the worst combination of the two forms. The result was that fiscal positions diverged significantly, which then created substantial spillovers for other euro area members. But perhaps more fundamentally, internal inconsistency meant that fiscal policy itself became ineffective in several jurisdictions. A number of governments either did not have the fiscal space to absorb the shock they faced in the early stage of the crisis, or they were unable to maintain the trust of the market when investors finally reacted – and over-reacted. Fiscal policy therefore had to effectively give up its stabilisation function – which is vital with a single monetary policy – and switch to convincing investors of debt sustainability. Prudential policies were also supposed to fit the decentralised model, although here the framework was even looser.