Response to consultation on separation of payment card schemes and processing entities under the IFR

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5. Do you have any other comments?

In point 3.1.10, It is highligted that the EBA is not able to ensure consistent implementation of the RTS as the related entities are not included in the scope of action of the EBA. We find this problematic and therefore propose that the EBA scope of action is adjusted so that implementation consistency of issued RTSes can be ensured.

Name of organisation

PAN-Nordic Card Association