Question ID
2024_7115
Legal act
Directive 2015/2366/EU (PSD2)
Topic
Authorisation and registration
Article
4
Paragraph
3
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
EBA/GL/2017/09 - Guidelines on authorisation and registration under PSD2
Article/Paragraph
4.1. Guideline 1 General principles
Name of institution / submitter
B-Efekt, a.s.
Country of incorporation / residence
Czech Republic
Type of submitter
Other
Subject matter
Providing payment service via Internet banking (web-application)
Question

Is providing payment service via Internet banking (web-application) payment initiation channel considered to be issuing of payment instruments? 

Background on the question

PSD2 Directive sets list of payment services, among which according to Annex  5. Issuing of payment instruments and/or acquiring of payment transactions. Payment instrument is defined as a personalised device(s) and/or set of procedures agreed between the payment service user and the payment service provider and used in order to initiate a payment order according to Article 4 (14).  Does the use of web-application (so-called internet-banking) or mobile application for providing other payment services (e.g. defined in Annex 1 p. 3 (a-c) and 4(a-c)) requires authorisation for service p.5 Issuing of payment instruments and/or acquiring of payment transactions?

Submission date
Status
Question under review
Answer prepared by
Answer prepared by the European Commission because it is a matter of interpretation of Union law.