Other retail deposits subject to higher outflow rates

Do the retail customers of financial institutions like challenger banks or fintechs whose clients specifically use mobile apps to sign up, log in, top up, use the features like payments, open savings accounts, invest, and etc comply with “an internet-access only account” definition? Is there a difference between customers who hold virtual cards and cannot access their funds via ATMs and the ones that have physical cards and can do so?

Under Delegated Regulation (EU) 2018/1620 with regard to liquidity coverage requirement, Article 25 states that other retail deposits shall be subject to higher outflow rates, as determined by the credit institution, in accordance with paragraph 3, where certain conditions are met including “the deposit is an internet-access only account”. Earlier on EBA has provided a comment in the Q/A question ID: 2019_4890 that “a retail deposit account, which can exclusively be serviced by telephone as well as by internet, should trigger the “internet access only” risk factor for high outflow classification”. However, this explanation is ambiguous for the challenger banks and fintechs whose clients specifically use mobile apps to sign up, log in, top up, use the features like payments, open savings accounts, invest, etc. These institutions tend to offer their clients virtual and/or physical cards. Physical card owners can access their funds via ATMs.