--- title: "EBA Q&A 2018_4429 — Q&A — Application of the Low Value Transaction Limits [Final Q&A]" shortTitle: "EBA Q&A 2018_4429 — Q&A — Application of the Low Value Transaction Limits [Final Q&A]" answer_id: EBA_QA_2018_4429 status: "Final Q&A" type: qa instrument_type: qa authority: EBA binding: false binding_character: non_binding legal_status: in_force regulation: "PSD2" psd2_level3: true mica_level2: false legal_basis: "Article 97 PSD2" date: 26 April 2019 source_link: https://www.eba.europa.eu/single-rule-book-qa/qna/view/publicId/2018_4429 lifecycle: "Final Q&A" text_version: "EBA Q&A register, 26 April 2019" source_url: "https://www.eba.europa.eu/single-rule-book-qa/qna/view/publicId/2018_4429" check_status: matched verified: true last_checked: 2026-10-26 checked_against: "the EBA publication" source: prepared_by: "EBA" published_by: "EBA" published_in: "EBA Single Rulebook Q&A tool" evidence: prepared_by: "Answer prepared by the EBA." locator: "EBA Q&A register entry 2018_4429, field 'Answer prepared by'" document_type: "qa_answer" legal_nature: "not_legislation" addressees: "not stated in the document" dates: published_on: "2019-04-26" question_submitted_on: "2018-12-20" locators: published_on: "EBA Q&A register entry 2018_4429, field 'Final publishing date'" question_submitted_on: "EBA Q&A register entry 2018_4429, field 'Submission date'" lifecycle_label: "Final Q&A" --- **Answer by the EBA, published in its Q&A tool · not legislation · published 26 Apr 2019 [Final Q&A]** *Final Q&A · EBA Q&A register, 26 April 2019 · Checked against the EBA publication on 26 Oct 2026 · [Official source](https://www.eba.europa.eu/single-rule-book-qa/qna/view/publicId/2018_4429)* | | | |---|---| | **Full title** | EBA Q&A 2018_4429 — Q&A — Application of the Low Value Transaction Limits \[Final Q&A\] | | **Prepared by** | EBA | | **Published by** | EBA, in the EBA Single Rulebook Q&A tool | | **Reference** | EBA_QA_2018_4429 | | **Document type** | Q&A | | **Legal nature** | Not legislation | | **Addressees** | Not stated in the document | | **Dates** | Published 26 April 2019; question submitted 20 December 2018 | | **Legal basis** | Article 97 PSD2 | | **Related instruments** | None recorded | | **Text on this page** | Word for word — the full text of the EBA publication | **Application of the Low Value Transaction Limits** ### Question Should the limits according the Article 16 RTS be applied to the account itself (account holder and authorized persons together) or should they be applied to the account holder (owner) and each authorized person (i.e. proxy of account holder) separately? Subsequently should the limits be applied to all remote payment transactions together or should e.g. card transactions and credit transfers be counted separately. Also should the limit be applied to all cards belonging to one person together or should the limit be applied to each card separately? ### Background Most of our clients have "family accounts" which are used by more than one person - the owner (or owners) and authorized persons (proxies) which can use account within certain boundaries set by the account owner. These authorized persons can even have multiple payment cards assigned to their name. We are unsure if the limits according the RTS should be applied to every single one owner/authorized person or if the limits should be combined for all of them together because the authorized person is still a person which is only allowed by the account owner to use his account in his name (i.e. in the name of the account owner). Subsequently should the limits of multiple payment cards of one person under one account be counted together or not? Because all transactions done by these cards are basically remote electronic payment transactions and according the wording of the article they should be counted together. Same applies to the "other types" of remote electronic payment transaction - should they be counted together with card payments and have a single one counter? *** ### Answer Article 16 of the Commission Delegated Regulation (EU) 2018/389 specifies that payment service providers shall be allowed not to apply strong customer authentication, where the payer initiates a remote electronic payment transaction provided that the conditions under items a-c of the same Article are met. Under Article 4(8) of PSD2, ‘payer’ is defined as ‘a natural or legal person who holds a payment account and allows a payment order from that payment account, or, where there is no payment account, a natural or legal person who gives a payment order’. Therefore, the limits specified under Article 16 of the Delegated Regulation shall be applied to the account holder. In the case where there is an authorised person acting on behalf of the account holder, the limits shall not be calculated separately. The limits specified under Article 16 of the Delegated Regulation, where the payer initiates a remote electronic payment transaction, shall be calculated at the level of each payment instrument separately. *** **Source:** [EBA original document](https://www.eba.europa.eu/single-rule-book-qa/qna/view/publicId/2018_4429) ## Related Level 1 articles - [Article 97 — Authentication](../../../articles/97.md)