- Question ID
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2019_5046
- Legal act
- Directive 2015/2366/EU (PSD2)
- Topic
- Fraud reporting
- Article
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96
- Paragraph
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6
- COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
- EBA/GL/2018/05 - Guidelines on fraud reporting under PSD2 (amended by EBA/GL/2020/01)
- Article/Paragraph
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Guideline 7.12
- Type of submitter
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Competent authority
- Subject matter
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Recording of card payments
- Question
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If a card has both an e-money and non e-money function, how should a payment be recorded? Should the recording be different based on the type of the reporting institution (for example, depending on whether is an electronic money institution (EMI) or a bank)?
- Background on the question
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Card payments should be reported differently under the EBA Guidelines on fraud under either Breakdowns C, D and/or F, depending on whether or not the card has an e-money function. However, it is not clear how card payments should be reported when the card has both an e-money and a non e-money function
- Submission date
- Final publishing date
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- Final answer
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In accordance with Guidelines 2.11, 7.11 and 7.12 of the EBA Guidelines on fraud reporting under PSD2 (EBA/GL/2018/05) as amended by the EBA Guidelines EBA/GL/2020/01, data for card payments should be reported both by the payer’s payment service provider (PSP) (the issuer), and by the payee’s PSP acquiring the payment transaction (the acquirer), as follows:
- from the issuer’s perspective, under the Data Breakdown C in Annex 2 of the Guidelines; and
- from the acquirer’s perspective, under the Data Breakdown D in Annex 2 of the Guidelines.
By contrast, “transactions and fraudulent transactions where e-money has been transferred by an e-money provider to a beneficiary account” should be reported in accordance with Guideline 1.5 from the payer’s PSP perspective only, under the Data Breakdown F in Annex 2 of the Guidelines.
Where a card has both an e-money and a non e-money function, the reporting will depend on which function of the card was used to conduct a particular transaction. If a debit or credit card function was used, then the payment should be reported as a card payment transaction under the Data Breakdown C from the issuer’s perspective and under the Data Breakdown D from the acquirer’s perspective. By contrast, if the e-money function of the card was used, then the payment should be reported as an e-money transaction under the Data Breakdown F only by the issuer.
The type of the reporting PSP, namely whether it is an electronic money institution or a credit institution, is not a relevant criterion for determining how these transactions should be reported.
- Status
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Final Q&A
- Answer prepared by
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Answer prepared by the EBA.