Recording of e-money

In accordance with Guideline 7.15 of the EBA Guidelines on fraud reporting under PSD2 (EBA/GL/2018/05) as amended by the EBA Guidelines EBA/GL/2020/01 , cash withdrawals and fraudulent cash withdrawals using a card at ATMs, at bank counters and through retailers (‘cash back’), should be reported by the issuing payment service provider (the issuer) in accordance with the Data Breakdown E in Annex 2 of the Guidelines. As regards reporting of e-money payment transactions, Guideline 7.2 provides that “when providing data on e-money transactions, the payment service provider (PSP) should include e-money payment transactions: a. where the PSP is identical to the payee’s PSP, or b. where a card with an e-money functionality is used.” However, this Guideline should be interpreted in conjunction with Guideline 1.5 which provides that “transactions and fraudulent transactions where e-money has been transferred by an e-money provider to a beneficiary account” should be reported in accordance with the Data Breakdown F. Cash withdrawals with e-money cards are not considered as “transfers” within the meaning of Guideline 1.5. Accordingly, cash withdrawals using cards with an e-money function, where the user redeems the e-money stored on the card by withdrawing funds, are out of scope of reporting under the EBA Guidelines on fraud reporting. By contrast, cash withdrawals using a payment card with a non e-money function, should be reported in accordance with Guideline 7.15 under the Data Breakdown E.