Re: Call for Consensus to Publish Payment Request API and Payment Method Identifiers as Recommendations - reply requested before 11 January 2022

2. Do not support the proposal – FORMAL OBJECTION

Criteo does not support the Payment Request API as is and is resubmitting a Formal Objection.

On October 28, Criteo raised a Formal Objection regarding the Payment Request API. Several items of this FO have been resolved through the pull request [1], and we thank the group for that.

One concern remains, for which we are maintaining our Formal Objection.

We think that there is some open-ended language [2] in the Payment Request API proposal that could be used by an implementer to justify preferencing one or several payment solutions or its own commercial interests that exceeds the scope of the working group to facilitate payments between users and merchants, and we think this should be addressed. For example, the current language states a user agent could show only its own payment solution “if the user agent wishes” or filter rivals’ solutions “at its discretion.” We believe the specification should be updated to explicitly address these uncharitable readings.

We are open to solutions such as:
-        Adding a generic statement related to the specification should not be used to restrict competition and/or violate the W3C Antitrust and Competition guidance
-        Adding language that would further restrict in which cases implementers might intervene in commercial transactions between users and merchants, such as “for security and privacy reasons”
-        Adding language that would directly tackle the competition concern, such as “to the exclusion of self-preferencing commercial interests of the implementer”
-        Removing or otherwise rephrasing the open-ended language to better capture the true intent of the working group
-        Or other alternatives that W3C members would suggest

In discussions with members, we did want to highlight a confusion we heard regarding our objection. We are not stating the specification itself must comply with all regional laws (e.g., we heard existing specifications knowingly violate some regional encryption laws) or for the W3C to police compliance with regional competition laws and agree that this is not the role of the W3C. Instead, our concern is narrowly focused on ensuring the specification itself abides by existing W3C policies.

[2] In paragraphs 3.3.6, 3.3.12, and 3.3.18 in<>

From: Ian Jacobs <>
Date: Tue, 4 Jan 2022 08:04:52 -0600
Message-Id: <>
To: Web Payments Working Group<>

Dear Web Payments Working Group Participants,

This is a Call for Consensus to publish the following specifications as W3C Recommendations:

  Payment Request API

  Payment Method Identifiers

We would like to thank the editors for preparing these documents.

PLEASE RESPOND to the proposal by 11 January 2022 (17h00 UTC).

For the co-Chairs,

Ian Jacobs



On 30 September 2021 the Director invited W3C Member review of

Proposed Recommendations of Payment Request API and Payment Method

Identifier. The review resulted in two Formal Objections to Payment

Request. The Editors made some non-substantive changes to the

specification to satisfy aspects of one of the Formal Objections (see


The Editors prepared a public record of the Formal Objections:

  Advisory Committee Review of Payment Request API and

  Payment Method Identifiers

We ask that the Working Group review the document and annotations

regarding the Formal Objections. This is a proposal to request that

the Director advance the specifications to Recommendation (per W3C

Process [1]).




(Since the 30 September 2021 Proposed Recommendation)

* Changes to address aspects of one Formal Objection:

* Informative changes to satisfy concerns raised by the

  Internationalization Working Group.

* An informative change due to a change in terminology in the

  URL specification:

* A small number of editorial changes to fix bugs.

For the full commit history, see:



That the Web Payments Working Group request that the W3C Director override the two Formal Objections and approve publication of Payment Request API and Payment Method Identifiers as Recommendations.

Please indicate one of the following in your response:

1. Support the proposal.

2. Do not support the proposal (please provide rationale).

3. Support the consensus of the Web Payments Working Group.

4. Abstain.

Rationale welcome in your response.

If there is consensus by 11 January 2022 (17h00 UTC) for the proposal, it will carry.



* If you wish your LACK of support to publish to be conveyed to the

  Director and reviewed, please include the phrase "FORMAL OBJECTION"

  in your response and be sure to include substantive arguments or

  rationale. The W3C Director takes Formal Objections seriously, and

  therefore they typically require significant time and effort to


* Silence will be taken to mean there is no Formal Objection.

* If there are new Formal Objections, the Chairs plan to contact the

  individual(s) who made them to see whether there are changes that

  would address the concern and increase consensus to publish.

For more information, see:



Transition Request Following a Working Group Decision to Publish

* In the case where this Call for Consensus results in a decision to

  publish, the Chairs plan to request approval from the W3C Director

  to publish Recommendations (including review of any Formal



Ian Jacobs <<>>

Tel: +1 917 450 8783

Received on Friday, 14 January 2022 13:34:34 UTC