Roles that can be assigned to electronic money institutions in certificates

Please clarify which roles may be assigned to electronic money institutions (EU 2015/2366 Art 1(1) b) by qualified trust service providers (QTSPs) in the certificates. There seems to be some contradiction between EU 2015/2366 Art 11(1) and the EBA Opinion on the use of eIDAS certificates under the RTS on SCA and CSC (EBA-Op-2018-7) item 26.

According to EU 2015/2366 Art 1(1) b) these institutions are exempted from getting an authorisation from a National Competent Authority (NCA) which we interpret in a way that they be granted PSP_AI, PSP_PI and PSP_IC roles. According to the EBA Opinion on the use of eIDAS certificates under the RTS on SCA and CSC (EBA-Op-2018-7) item 26 only roles can be assigned for which the institution is authorized “Therefore, the roles that could be assigned to electronic money institutions that would like to obtain an eIDAS certificate should also be limited to the payment services for which the respective electronic money institution has been authorised.” We note that NCAs handle this in different ways. Member State A: Its NCA's Payment Institutions Register currently includes 8 electronic money institutions all having authorized services “E-Geld Geschäft (§ 1 Abs. 2 Satz 2 ZAG)”. BaFin has published a note stating that e-Money institutions can act as PSP_AI, PSP_PI, PSP_IC automatically.  Member State B: Its NCA has 13 electronic money institutions. Specific roles like “Acquiring of payment transactions” are assigned to them, none of them has any of the PSD2 roles. Country C:  Its NCA has assigned individual roles to their electronic money institutions, some of them have PSD2 roles.