Services offered by means of ATM by providers

Which is the appropriate payment service for ATM withdrawals, where the ATM provider is required to be authorised but is acting on behalf of one or more card issuers, which are not a party to the framework contract with the customer withdrawing money from a payment account?

Where a firm is providing cash withdrawal services offered by means of ATM, acting on behalf of one or more card issuers, which are not a party to the framework contract with the customer withdrawing money from a payment account, but is also conducting other payment services, the exemption in Article 3(o) makes it clear that authorisation is required. What is not clear is which of the payment services listed in Annex 1 to the Directive the ATM cash withdrawals should correctly be classified under. This could be: - 2. Services enabling cash withdrawals from a payment account (although this permission also includes "as well as all the operations required for operating a payment account."); or 3(b) Execution of payment transactions, including transfers of funds on a payment account with the user’s payment service provider or with another payment service provider: (b) execution of payment transactions through a payment card or a similar device.