--- title: "EBA Q&A 2023_6788 — Q&A — Fraud reporting [Final Q&A]" shortTitle: "EBA Q&A 2023_6788 — Q&A — Fraud reporting [Final Q&A]" answer_id: EBA_QA_2023_6788 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: 14 June 2024 source_link: https://www.eba.europa.eu/single-rule-book-qa/qna/view/publicId/2023_6788 lifecycle: "Final Q&A" text_version: "EBA Q&A register, 14 June 2024" source_url: "https://www.eba.europa.eu/single-rule-book-qa/qna/view/publicId/2023_6788" 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 2023_6788, field 'Answer prepared by'" document_type: "qa_answer" legal_nature: "not_legislation" addressees: "not stated in the document" dates: published_on: "2024-06-14" question_submitted_on: "2023-04-28" locators: published_on: "EBA Q&A register entry 2023_6788, field 'Final publishing date'" question_submitted_on: "EBA Q&A register entry 2023_6788, field 'Submission date'" lifecycle_label: "Final Q&A" --- **Answer by the EBA, published in its Q&A tool · not legislation · published 14 Jun 2024 [Final Q&A]** *Final Q&A · EBA Q&A register, 14 June 2024 · Checked against the EBA publication on 26 Oct 2026 · [Official source](https://www.eba.europa.eu/single-rule-book-qa/qna/view/publicId/2023_6788)* | | | |---|---| | **Full title** | EBA Q&A 2023_6788 — Q&A — Fraud reporting \[Final Q&A\] | | **Prepared by** | EBA | | **Published by** | EBA, in the EBA Single Rulebook Q&A tool | | **Reference** | EBA_QA_2023_6788 | | **Document type** | Q&A | | **Legal nature** | Not legislation | | **Addressees** | Not stated in the document | | **Dates** | Published 14 June 2024; question submitted 28 April 2023 | | **Legal basis** | Article 96(6) PSD2 | | **Related instruments** | None recorded | | **Text on this page** | Word for word — the full text of the EBA publication | **Fraud reporting** ### Question How we should treat the transactions that are initiated by PSP (for example refunds, chargebacks, etc.), but those transactions are related to cardholder's actions. ### Background As per guidelines 3.1/7.11 transactions should be reported by initiator to avoid doubling of transactions reported by several entities. We have doubts if direct transfers like MoneySend, refund, reversal, chargeback and 2nd presentment the Issuer isn’t an initiator of these transactions, hence we are looking for legitimate confirmation. *** ### 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, payment transactions and fraudulent payment transactions where a payment card was used 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. As clarified in Q&A 4855, a refund initiated by a merchant, which in this case acts in its capacity as a payer, is an electronic payment transaction initiated by the payer. Accordingly, refunds initiated by a merchant using a payment card and refunds as a chargeback to the issuer should be reported in accordance with Guidelines 2.11, 7.11 and 7.12. *** **Source:** [EBA original document](https://www.eba.europa.eu/single-rule-book-qa/qna/view/publicId/2023_6788) ## Related Level 1 articles - [Article 96 — Incident reporting](../../../articles/96.md)