PSD2 requires 15 days. kazva.bg tracks every one.
Payment service providers must respond to complaints within 15 working days. EBA guidelines mandate a dedicated complaints management function.
Mandatory Requirement
Payment Services Act (ЗПУПС, PSD2 transposition), Art. ~174:
- Payment service providers MUST respond to complaints within 15 working days
- Extension to 35 working days only for reasons beyond the provider's control
- Failed/unsatisfied complaints go to the Payment Disputes Conciliation Commission at BNB
EBA/ESMA Joint Committee Guidelines (JC 2018 35):
- Complaints management policy required
- Dedicated complaints management function
- Registration, reporting, internal follow-up, and response procedures - all mandatory for supervised institutions
Payment Services and Payment Systems Act (ЗПУПС); EBA/ESMA Joint Committee Guidelines on complaints-handling (JC 2018 35)
European Banking: Dual Supervision and Escalating Complaint Requirements
Since joining the ERM II and the EU Banking Union, financial institutions in EU member states face dual supervisory oversight — national central banks and the ECB/EBA. PSD2 (Directive 2015/2366), transposed into national law across Europe, obliges every payment service provider to respond to complaints within 15 working days. National conciliation commissions handle unresolved cases — the volume of formal complaints reaching these bodies has been growing steadily across the EU, putting pressure on banks to resolve issues proactively.
EBA Guidelines and Why Automation Is Critical
The EBA/ESMA Joint Committee Guidelines (JC 2018 35) require every supervised institution to maintain a dedicated complaints management function that registers, categorizes, and tracks every complaint with timestamps. During audits by national or European supervisors, banks must present evidence of this function's effectiveness — complaint volumes, response times, categories, and corrective actions taken. Manual tracking via spreadsheets no longer meets regulatory expectations.
kazva.bg automates complaint registration and categorization in real time. QR codes at bank counters and self-service zones allow customers to submit feedback on the spot, without going through formal complaint procedures. All data is exported with timestamps — ready for regulatory auditors and internal EBA compliance reporting. FinTech challengers routinely achieve NPS scores of 80-90, compared to 7-30 for traditional banks, making customer experience a competitive differentiator as well as a compliance necessity.
What the law requires
15-day complaint response SLA (Payment Services Act)
kazva.bg: Partial
Complaints management function (EBA/ESMA)
kazva.bg: Partial
Complaint registration and reporting
kazva.bg: Covered
Applicable standards
| Standard | Description | Relevance |
|---|---|---|
| ISO 10002:2018 | Quality management - Customer satisfaction - Complaints handling Full standard | THE complaints handling standard - kazva.bg provides documented complaint capture, categorization, and response time tracking. |
| EN ISO 9001:2015 | Quality management systems §9.1.2 Customer satisfaction | Financial institutions with ISO 9001 certification must demonstrate systematic customer satisfaction measurement. |
Industry benchmarks
| Level | NPS |
|---|---|
| Good | 35+ |
| Average | 20–34 |
| Poor | <20 |
EPSI Netherlands 2024: sector average 67.2; CustomerGauge: Banking avg NPS 30; NPS Prism 2024: 190,000+ customers, 141 banks, 10 European countries
FinTech dramatically outperforms traditional banking (NPS 80-90 vs 7-30). European data from EPSI Rating covers Nordic/NL markets.