Card payments - acquirer

EBA Guidelines on fraud reporting under the PSD2 (EBA/GL/2018/05), as amended by the EBA Guidelines EBA/GL/2020/01, provide that payments with cards with an e-money function only (e.g. prepaid cards) should not be included as card payments but be reported as e-money. 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.” This Guideline should be interpreted in conjunction with Guideline 1.5, which prescribes that “transactions and fraudulent transactions where e-money has been transferred by an e-money provider to a beneficiary account […] should be reported by the e-money provider in accordance with Data Breakdown F in Annex 2.” Guideline 1.5 also specifies that reporting should be done by the payer’s payment service provider only. This approach is different to the reporting of card payments, where the transactions should be reported from both the payer’s payment service provider (issuer) and the payee’s payment service provider (acquirer). However, it should be noted that the Guidelines do not explicitly prescribe the reporting of transactions and fraudulent transactions in case the acquirer is not able to identify the type of card being used (i.e. e-money or payment card).  In case the acquirer cannot identify the type of card being used, it is preferable for the acquirer to report the transactions under Table D “Data breakdown for card-based payments transactions to be reported by the acquiring payment service provider (with a contractual relationship with the payment service user)”.