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---
title: "EBA Q&A 2019_4982 — Q&A — Services offered by means of ATM by providers [Rejected question]"
shortTitle: "EBA Q&A 2019_4982 — Q&A — Services offered by means of ATM by providers [Rejected question]"
answer_id: EBA_QA_2019_4982
status: "Rejected question"
type: qa
instrument_type: qa
authority: EBA
binding: false
binding_character: non_binding
legal_status: withdrawn
regulation: "PSD2"
psd2_level3: true
mica_level2: false
legal_basis: "Article 3 PSD2"
date: 11 February 2022
source_link: https://www.eba.europa.eu/single-rule-book-qa/qna/view/publicId/2019_4982
lifecycle: "Rejected question"
text_version: "EBA Q&A register, 11 February 2022"
source_url: "https://www.eba.europa.eu/single-rule-book-qa/qna/view/publicId/2019_4982"
check_status: matched
verified: true
last_checked: 2026-10-26
checked_against: "the EBA publication"
source:
  prepared_by: "not stated in the document"
  published_by: "EBA"
  published_in: "EBA Single Rulebook Q&A tool"
  evidence:
    prepared_by: "Consultancy firm"
    locator: "EBA Q&A register entry 2019_4982: no answer; the register names only the 'Type of submitter'"
document_type: "qa_question"
legal_nature: "not_legislation"
addressees: "not stated in the document"
dates:
  published_on: "2022-02-11"
  question_submitted_on: "2019-11-04"
  locators:
    published_on: "EBA Q&A register entry 2019_4982, field 'Rejected publishing date'"
    question_submitted_on: "EBA Q&A register entry 2019_4982, field 'Submission date'"
lifecycle_label: "Rejected question"
---

**Question published in the EBA Q&A tool · no answer · not legislation · published 11 Feb 2022 [Rejected question]**

*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_4982)*

| | |
|---|---|
| **Full title** | EBA Q&A 2019_4982 — Q&A — Services offered by means of ATM by providers \[Rejected question\] |
| **Prepared by** | Not stated in the document |
| **Published by** | EBA, in the EBA Single Rulebook Q&A tool |
| **Reference** | EBA_QA_2019_4982 |
| **Document type** | Q&A |
| **Legal nature** | No answer · not legislation |
| **Addressees** | Not stated in the document |
| **Dates** | Published 11 February 2022; question submitted 4 November 2019 |
| **Legal basis** | Article 3 PSD2 |
| **Related instruments** | None recorded |
| **Text on this page** | Word for word — the full text of the EBA publication |

**Services offered by means of ATM by providers**

### Question

Which is the appropriate payment service for ATM withdrawals, where the ATM provider is required to be authorised but is acting on behalf of one or more card issuers, which are not a party to the framework contract with the customer withdrawing money from a payment account?

### Background

Where a firm is providing cash withdrawal services offered by means of ATM, acting on behalf of one or more card issuers, which are not a party to the framework contract with the customer withdrawing money from a payment account, but is also conducting other payment services, the exemption in Article 3(o) makes it clear that authorisation is required. What is not clear is which of the payment services listed in Annex 1 to the Directive the ATM cash withdrawals should correctly be classified under. This could be: -

2. Services enabling cash withdrawals from a payment account (although this permission also includes "as well as all the operations required for operating a payment account."); or

3(b) Execution of payment transactions, including transfers of funds on a payment account with the user’s payment service provider or with another payment service provider:

(b) execution of payment transactions through a payment card or a similar device.

***

### Answer

Please 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.

If 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.

For further information please refer to the press release and the updated Q&A page.

***

**Source:** [EBA original document](https://www.eba.europa.eu/single-rule-book-qa/qna/view/publicId/2019_4982)

## Related Level 1 articles

- [Article 3 — Exclusions](../../../articles/3.md)