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the register names only the 'Type of submitter'\"\ndocument_type: \"qa_question\"\nlegal_nature: \"not_legislation\"\naddressees: \"not stated in the document\"\ndates:\n  published_on: \"2022-02-11\"\n  question_submitted_on: \"2019-02-26\"\n  locators:\n    published_on: \"EBA Q&A register entry 2019_4576, field 'Rejected publishing date'\"\n    question_submitted_on: \"EBA Q&A register entry 2019_4576, field 'Submission date'\"\nlifecycle_label: \"Rejected question\"\n---\n\n**Question published in the EBA Q&A tool · no answer · not legislation · published 11 Feb 2022 [Rejected question]**\n\n*Rejected question · EBA Q&A register, 11 February 2022 · Checked against the EBA publication on 26 Oct 2026 · [Official source](https://www.eba.europa.eu/single-rule-book-qa/qna/view/publicId/2019_4576)*\n\n| | |\n|---|---|\n| **Full title** | EBA Q&A 2019_4576 — Q&A — Surcharging \\[Rejected question\\] |\n| **Prepared by** | Not stated in the document |\n| **Published by** | EBA, in the EBA Single Rulebook Q&A tool |\n| **Reference** | EBA_QA_2019_4576 |\n| **Document type** | Q&A |\n| **Legal nature** | No answer · not legislation |\n| **Addressees** | Not stated in the document |\n| **Dates** | Published 11 February 2022; question submitted 26 February 2019 |\n| **Legal basis** | PSD2 |\n| **Related instruments** | None recorded |\n| **Text on this page** | Word for word — the full text of the EBA publication |\n\n**Surcharging**\n\n### Question\n\nIs a ‘foreign exchange margin’ or 'currency conversion fee' different from a ‘surcharge’ and do different foreign exchange margins above the ECB mid-market rate not constitute a surcharge?\n\n### Background\n\nRecital 66 of PSD2 refers to ‘charging for the use of a given payment instrument (surcharging)’. In some cross-border situations Payment Services Providers (PSPs) or merchants may wish to accept a payment from a consumer in the consumers’ own currency. Through doing this, the merchant or PSP may take on risk in the form of movements in the foreign exchange market, however, the consumer would benefit through having additional choice of ways to pay. Once the funds are collected from the consumer, the PSP or merchant would gather all funds received in that currency and conduct a foreign exchange transaction with its own credit institution, into the PSPs own currency. This would occur on a periodic basis, typically at the end of each business day. However, when providing a rate to the consumer the PSP may not know the precise foreign exchange rate which the PSP itself will be charged at the end of the day and therefore must approximate the rate which to charge its own consumer. In some situations, relative to the ECB mid-market rate, the consumer would have inadvertently been charged a fee or margin (when the amount charged to the consumer is higher than the rate the PSP paid) and in other cases a discount (when the amount charged to the consumer is low than the rate the PSP paid).\n\nThere appears to be confusion amongst consumers and merchants in non-Euro EU countries where merchants or PSPs who wish to provide choice and convenience are being accused of surcharging where this is not the case. Specifically in ticket purchases, such as airline tickets or utility bill/invoice payments. These companies may wish to offer the consumer the ability to pay in their local currency rather than the PSP or merchants currency.\n\n***\n\n### Answer\n\nPlease note that as part of adjustments to the Single Rulebook Q&A process, agreed by the EBA and the European Commission, it has been decided to reject outstanding questions submitted before 1 January 2020, when the Q&A process was updated as part of the last ESAs Review. In particular, the question that you have submitted has now regrettably been rejected and will not be addressed.\n\nIf you believe your question would still benefit from clarification, you are invited to resubmit your question, adapting it to reflect any legislative, regulatory or other relevant developments that may have occurred since the initial date of submission. The EBA will aim to address resubmitted questions as a matter of priority. When considering to resubmit, you are kindly requested to observe the updated admissibility criteria agreed in the context of the adjustment of the Q&A process, available in the Additional background and guidance for asking questions. We hope for your understanding.\n\nFor further information please refer to the press release and the updated Q&A page.\n\n***\n\n**Source:** [EBA original document](https://www.eba.europa.eu/single-rule-book-qa/qna/view/publicId/2019_4576)\n"}