--- title: "EBA Q&A 2019_5046 — Q&A — Recording of card payments [Final Q&A]" shortTitle: "EBA Q&A 2019_5046 — Q&A — Recording of card payments [Final Q&A]" answer_id: EBA_QA_2019_5046 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 96(6) PSD2" date: 24 July 2020 source_link: https://www.eba.europa.eu/single-rule-book-qa/qna/view/publicId/2019_5046 lifecycle: "Final Q&A" text_version: "EBA Q&A register, 24 July 2020" source_url: "https://www.eba.europa.eu/single-rule-book-qa/qna/view/publicId/2019_5046" 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 2019_5046, field 'Answer prepared by'" document_type: "qa_answer" legal_nature: "not_legislation" addressees: "not stated in the document" dates: published_on: "2020-07-24" question_submitted_on: "2019-12-13" locators: published_on: "EBA Q&A register entry 2019_5046, field 'Final publishing date'" question_submitted_on: "EBA Q&A register entry 2019_5046, field 'Submission date'" lifecycle_label: "Final Q&A" --- **Answer by the EBA, published in its Q&A tool · not legislation · published 24 Jul 2020 [Final Q&A]** *Final Q&A · EBA Q&A register, 24 July 2020 · Checked against the EBA publication on 26 Oct 2026 · [Official source](https://www.eba.europa.eu/single-rule-book-qa/qna/view/publicId/2019_5046)* | | | |---|---| | **Full title** | EBA Q&A 2019_5046 — Q&A — Recording of card payments \[Final Q&A\] | | **Prepared by** | EBA | | **Published by** | EBA, in the EBA Single Rulebook Q&A tool | | **Reference** | EBA_QA_2019_5046 | | **Document type** | Q&A | | **Legal nature** | Not legislation | | **Addressees** | Not stated in the document | | **Dates** | Published 24 July 2020; question submitted 13 December 2019 | | **Legal basis** | Article 96(6) PSD2 | | **Related instruments** | None recorded | | **Text on this page** | Word for word — the full text of the EBA publication | **Recording of card payments** ### Question If a card has both an e-money and non e-money function, how should a payment be recorded? Should the recording be different based on the type of the reporting institution (for example, depending on whether is an electronic money institution (EMI) or a bank)? ### Background Card payments should be reported differently under the EBA Guidelines on fraud under either Breakdowns C, D and/or F, depending on whether or not the card has an e-money function. However, it is not clear how card payments should be reported when the card has both an e-money and a non e-money function *** ### Answer In accordance with Guidelines 2.11, 7.11 and 7.12 of the EBA Guidelines on fraud reporting under PSD2 (EBA/GL/2018/05) as amended by the EBA Guidelines EBA/GL/2020/01, data for card payments should be reported both by the payer’s payment service provider (PSP) (the issuer), and by the payee’s PSP acquiring the payment transaction (the acquirer), as follows: from the issuer’s perspective, under the Data Breakdown C in Annex 2 of the Guidelines; and from the acquirer’s perspective, under the Data Breakdown D in Annex 2 of the Guidelines. By contrast, “transactions and fraudulent transactions where e-money has been transferred by an e-money provider to a beneficiary account” should be reported in accordance with Guideline 1.5 from the payer’s PSP perspective only, under the Data Breakdown F in Annex 2 of the Guidelines. Where a card has both an e-money and a non e-money function, the reporting will depend on which function of the card was used to conduct a particular transaction. If a debit or credit card function was used, then the payment should be reported as a card payment transaction under the Data Breakdown C from the issuer’s perspective and under the Data Breakdown D from the acquirer’s perspective. By contrast, if the e-money function of the card was used, then the payment should be reported as an e-money transaction under the Data Breakdown F only by the issuer. The type of the reporting PSP, namely whether it is an electronic money institution or a credit institution, is not a relevant criterion for determining how these transactions should be reported. *** **Source:** [EBA original document](https://www.eba.europa.eu/single-rule-book-qa/qna/view/publicId/2019_5046) ## Related Level 1 articles - [Article 96 — Incident reporting](../../../articles/96.md)