This question has been raised previously, but is resubmitted because it would still benefit from clarification.

In the context of an application for authorisation as payment service provider under PSD2, this question is raised with regard to determining whether or not the intended activities of the applicant qualify as payment services, more explicitly if the fuel card qualifies as a payment instrument. In order to be compliant with Article 37 PSD2, it is required to establish if the services provided qualify as payment services under PSD2. In this case, it concerns a fuel card, for which the applicant seeks authorisation under PSD2. Besides this application, we receive several notifications from issuers of fuel cards, to qualify under the limited network exclusion of Article 3(k). In those cases, we need to make a decision if a given solution meets the requirements of limited network exclusion. However to apply an exclusion, or - in the current procedure - to grant authorisation, we should first establish that the solution falls under the definition of one of the payment services described in PSD2. Mostly, it is issuing of payment instruments and/or acquiring of payment transactions. Therefore, the question occurred that a given solution (e.g. a fuel card) based on the business model can be considered as payment instrument hence the CAs should consider the granting of an authorisation of the application of an exclusion. In this case, a multinational oil company has explained that the fuel cards are not used for initiating the payment transaction, in other words there is no payment order given with the card itself, but the card services the purpose of identification and an “authorisation” of the fact whether the oil company issued the fuel card has a deferred payment agreement with the card holder. After a certain period, a formal invoice is issued and the settlement of the invoice is done via a regular credit transfer. Should a (fuel) card that  is functions as such, be considered to consitute a payment instrument?