EMA publications

The EMA frequently responds to government and European consultations on regulation that impacts the e-money and payment services industry. Sometimes, we also express our views on issues that are raised in the public domain where we feel it is important to provide an industry input.

Our publications reflect the views of the EMA as whole; individual members’ views may vary from time to time. The public consultation responses are listed below. For further information on these positions, please contact us.

Is this the end of interoperable electronic money?

EMA COMMENTARY

The European Commission’s Q&A 2022_6336 deals with scheme branded prepaid cards and specifically whether they fall within the definition of e-money. Prior to the Q&A such prepaid cards were accepted as e-money across the EU.

The  guidance that it provides: narrows down what products can be  electronic money, restricting them to three-party systems. This is where both payer and payee contract directly with a payment service provider (“PSP”). It effectively prohibits any four-party, interoperable, e-money systems, whether national or cross border. Four-party systems are those where the payer and payee can contract with different PSPs, as would be the case for example with interbank payment schemes such as SEPA or card schemes such as Mastercard or Visa. Four-party systems enable different issuers to interoperate with each other, where the e-money issued by one is accepted by merchants of another.

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