The RTS set out a number of thresholds for the application of certain exemptions. In particular:
(a) The exemption for low-value contactless transactions is applicable where the individual amount of each contactless transaction “does not exceed EUR 50” and the cumulative amount of previous contactless transactions “does not exceed EUR 150” (Article 11 RTS);
(b) The exemption for low-value remote transactions is applicable where the individual amount of each remote transaction “does not exceed EUR 30” and the cumulative amount of previous remote transactions “does not exceed EUR 100” (Article 16 RTS);
(c) The transaction risk analysis (TRA) exemption is applicable where the exempted threshold values (ETV) of EUR 100, 250 and 500 are not exceeded (Article 18 RTS and Annex I to the RTS).
All these thresholds are formulated in EUR only. However, 12 out of the 31 EEA countries where the RTS will apply do not use EUR. These are Bulgaria, Croatia, Czech Republic, Denmark, Hungary, Iceland, Liechtenstein, Norway, Poland, Romania, Sweden and United Kingdom.
We believe that PSPs and card schemes may set rounded non-EUR currency equivalents for the EUR thresholds set out in the RTS. In particular, setting rounded and easily understandable figures in non-EUR currencies would facilitate the application of the RTS in non-euro EEA countries. PSPs could communicate to their merchants and cardholders rounded figures in their domestic currencies so that thresholds can be conveniently applied.
For non-Euro transactions, the payment service providers (PSPs) and card schemes should convert EUR thresholds as required under Articles 11, 16, 18 of the Commission Delegated Regulation (EU) 2018/389 into non-Euro currency thresholds, using the average ECB reference exchange rate. In practice, PSPs and card schemes may wish to keep the threshold in Euros.
Rounding of the threshold amount in non-Euro currency could only be done if the threshold in the other currency is rounded to a value, which is unlikely to breach the EUR threshold in the Delegated Regulation, based on the ECB reference exchange rate information. Any such rounded amount may require adjusting from time to time. For example, the EUR 50 threshold for remote payments would be equivalent to a UK sterling threshold of £44.50 as of 12 September 2018; the lowest it would have been over the previous 12 months is £43. So if the UK sterling threshold was rounded down to £40, it would likely always comply with the EUR 50 threshold for the period given in this example (September 2017 – September 2018).