EBA E-mail alert July 11, 2025

What devices or procedures can be considered as payment instrument as per Art. 4(14) of PSD2?

1. Should postal transfers as defined by the Universal Postal Union, which are not made in paper form but by electronic means, be excluded from the scope of PSD2?  

2. If postal transfers, as defined by the Universal Postal Union, in both electronic and paper format, are inseparable from the postal operator’s accounting system, should also paper-based postal transfers not fall outside the scope of PSD2?  

3. Should such transfers be excluded from the scope of PSD2 in either case, or agree that the payment institution is not entitled to credit those funds to the payment service customers’ funds accounts where the money of the payment service users is kept separate?  

4. Can a payment institution that is also a postal service provider simultaneously provide both PSD2 regulated services and services related to payments but outside the scope of PSD2?

Does this credit qualify as consumer credit, exclusively available to individual consumers? Or can it also be extended to legal entities?

How should wholesale term deposits be allocated in the available time buckets of c66.01, in case there is an early withdrawal penalty?