--- title: "EBA Q&A 2020_5573 — Q&A — Information to be provided by the PISP to the payer prior [Final Q&A]" shortTitle: "EBA Q&A 2020_5573 — Q&A — Information to be provided by the PISP to the payer prior [Final Q&A]" answer_id: EBA_QA_2020_5573 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: "PSD2" date: 3 December 2021 source_link: https://www.eba.europa.eu/single-rule-book-qa/qna/view/publicId/2020_5573 lifecycle: "Final Q&A" text_version: "EBA Q&A register, 3 December 2021" source_url: "https://www.eba.europa.eu/single-rule-book-qa/qna/view/publicId/2020_5573" check_status: matched verified: true last_checked: 2026-10-26 checked_against: "the EBA publication" source: prepared_by: "European Commission" published_by: "EBA" published_in: "EBA Single Rulebook Q&A tool" evidence: prepared_by: "Answer prepared by the European Commission because it is a matter of interpretation of Union law." locator: "EBA Q&A register entry 2020_5573, field 'Answer prepared by'" document_type: "qa_answer" legal_nature: "not_legislation" addressees: "not stated in the document" dates: published_on: "2021-12-03" question_submitted_on: "2020-10-20" locators: published_on: "EBA Q&A register entry 2020_5573, field 'Final publishing date'" question_submitted_on: "EBA Q&A register entry 2020_5573, field 'Submission date'" lifecycle_label: "Final Q&A" --- **Answer prepared by the European Commission, published in the EBA Q&A tool · not legislation · published 3 Dec 2021 [Final Q&A]** *Final Q&A · EBA Q&A register, 3 December 2021 · Checked against the EBA publication on 26 Oct 2026 · [Official source](https://www.eba.europa.eu/single-rule-book-qa/qna/view/publicId/2020_5573)* | | | |---|---| | **Full title** | EBA Q&A 2020_5573 — Q&A — Information to be provided by the PISP to the payer prior \[Final Q&A\] | | **Prepared by** | European Commission | | **Published by** | EBA, in the EBA Single Rulebook Q&A tool | | **Reference** | EBA_QA_2020_5573 | | **Document type** | Q&A | | **Legal nature** | Not legislation | | **Addressees** | Not stated in the document | | **Dates** | Published 3 December 2021; question submitted 20 October 2020 | | **Legal basis** | PSD2 | | **Related instruments** | None recorded | | **Text on this page** | Word for word — the full text of the EBA publication | **Information to be provided by the PISP to the payer prior to the initiation of the transaction** ### Question Is it sufficient that the merchant makes available upon request by the payer (consumer) the information about the Payment Initiation Service Provider (PISP) in the Point of Interaction (POI) environment before the consumer presents their data (e.g., via a QR code) to meet the requirements of Articles 44 and 45, (2), PSD2? ### Background Articles 44 and 45, (2), PSD2, set out the information to be provided to the payer by the PISP, about the PISP, prior to the initiation of a transaction. Typically for (instant) credit transfers at the POI based on consumer-presented data (e.g. a QR-code with CustomerID and IBAN read by the merchant POI), a PISP is involved on the merchant side, and has a contractual relationship with the merchant to initiate the transaction, but might not have any prior contractual relationship with the consumer (e.g. in case of a single transaction). It is unclear how a PISP can provide or make available to the payer the information on the PISP required under Article 45 (2), PSD2, for (instant) credit transfers at the POI based on consumer-presented data (e.g. a QR-code with CustomerID and IBAN read by the merchant POI), where typically a PISP has a contractual relationship with the merchant to initiate the transaction but where the same PISP may not have any prior contractual relationship with the consumer? Is it sufficient that the merchant makes available,, upon request by the payer (consumer), the information about the PISP in the POI environment before the consumer presents their data (e.g., via a QR code) to meet the requirements of Articles 44 and 45, (2), PSD2? *** ### Answer The information to be provided, within the meaning of Article 45(2) of Directive (EU) 2015/2366 (PSD2) read in conjunction with Article 44 PSD2, can be provided by the merchant acting on behalf of the Payment Information Service Provider (PISP), as long as it is provided in an easily accessible manner, as specified in the first sentence of Article 44(1) PSD2. Cases where the provision of information by the payment service provider to the payment service user requires a prior request from the latter are clearly stipulated in PSD2 (cf. Article 44(1), second sentence, Article 53). Article 45(2) PSD2 does not refer to a payer’s prior request. The PISP, or the merchant acting on its behalf, should therefore provide or make available to the payer the information under Article 45(2) PSD2 without being requested to do so by the latter. Disclaimer: The answers clarify provisions already contained in the applicable legislation. They do not extend in any way the rights and obligations deriving from such legislation nor do they introduce any additional requirements for the concerned operators and competent authorities. The answers are merely intended to assist natural or legal persons, including competent authorities and Union institutions and bodies in clarifying the application or implementation of the relevant legal provisions. Only the Court of Justice of the European Union is competent to authoritatively interpret Union law. The views expressed in the internal Commission Decision cannot prejudge the position that the European Commission might take before the Union and national courts. *** **Source:** [EBA original document](https://www.eba.europa.eu/single-rule-book-qa/qna/view/publicId/2020_5573)