Submission #42

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OnShop S.r.l.

Q1. Do you have comments on Guideline 1 on the specific payment instruments under Article 3(k) of PSD2?

1.4- If the meaning of "user" is related to the merchant accepting the payment instrument the article is clear otherwise it should be explained

Q2. Do you have comments on Guideline 2 on the limited network of service providers under Article 3(k)(i) of PSD2?

2.1 (b) The maximum number of providers should be indicated
2.1 (c) The "size" of the geographic is not pertaining in respect of PSD2 Art. 3(k)(i)
2.2 (a) The "size" of the geographic is subjective and not objective
2.2 (b) the volume of payment transaction should be indicated
If no value is given for all the art. 2.2 items, all the evaluations could be subjective and not objective.

Q3. Do you have comments on Guideline 3 on the instruments used within the premises of the issuer under Article 3(k)(i) of PSD2?

It is not clear the scope of this limitation. If the goods are not physical the only way to deliver to the customer is in a digital way thorough a issuer marketplace how can be the goods can be delivered?

Q4. Do you have comments on Guideline 4 on the limited range of goods or services under Article 3(k)(ii) of PSD2? None

Q5. Do you have comments on Guideline 5 on the provision of services under Article 3(k) of PSD2 by regulated entities? None

Q6. Do you have comments on Guideline 6 on the notifications under Article 37(2) of PSD2? None

Q7. Do you have comments on Guideline 7 on the limited network under Article 3(k)(iii) of PSD2? Already commented in Q2

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Name of the organization OnShop S.r.l.