Multi-licensed entity capital requirement

Should a payment institution that also has a crowdfunding license meet the capital requirements of both authorizations in aggregate?

A crowdfunding service provider may itself, or through a third party, provide payment services according to the article 8 paragraph 4 stemming from Regulation (EU) 2020/1503 of the European Parliament and of the Council of 7 October 2020 on European crowdfunding service providers for business, and amending Regulation (EU) 2017/1129 and Directive (EU) 2019/1937. That means, crowdfunding service providers may hold payment institution (PI) license and vice versa. If a PI entity is also authorized as a crowdfunding service provider, it needs to meet both capital requirements. PSD2 article 8 paragraph 2 states that Member States shall take the necessary measures to prevent the multiple use of elements eligible for own funds where the payment institution belongs to the same group as another payment institution, credit institution, investment firm, asset management company or insurance undertaking. This paragraph shall also apply where a payment institution has a hybrid character and carries out activities other than providing payment services. Last sentence of the before mentioned paragraph says that if payment institution has a hybrid character and carries out activities other than providing payment services, then own funds elements can’t be used multiple times. Unfortunately, it has not been further clarified whether ban of multiple use means aggregating the capital requirements of both licenses. For example: same entity holds both PI and crowdfunding service provider authorizations. For example own funds requirement for PI is 2 EUR and own funds requirements for crowdfunding service is 1 EUR. If PSD2 article 8 paragraph 2 means aggregation of own funds, then entity holding two authorizations would have to meet the both capital requirement separately i.e. 1+2=3. If PSD 2 article 8 paragraph 2 doesn’t mean aggregation of own funds, but application of a higher capital requirement, which also covers the lower capital requirement resulting from the second authorization, then entity should have own funds in the sum of 2, that covers both capital requirements considered separately (non aggregated).