--- title: "EBA Q&A 2026_7760 — Q&A — Ban imposed by certain national authorities [Rejected question]" shortTitle: "EBA Q&A 2026_7760 — Q&A — Ban imposed by certain national authorities [Rejected question]" answer_id: EBA_QA_2026_7760 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question" type: qa instrument_type: qa authority: EBA binding: false binding_character: non_binding legal_status: withdrawn regulation: "PSD2" psd2_level3: true mica_level2: false legal_basis: "PSD2" date: 15 June 2026 source_link: https://www.eba.europa.eu/single-rule-book-qa/qna/view/publicId/2026_7760 lifecycle: "Rejected question" text_version: "EBA Q&A register, 15 June 2026" source_url: "https://www.eba.europa.eu/single-rule-book-qa/qna/view/publicId/2026_7760" 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: "Other" locator: "EBA Q&A register entry 2026_7760: 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: "2026-06-15" question_submitted_on: "2026-03-11" locators: published_on: "EBA Q&A register entry 2026_7760, field 'Rejected publishing date'" question_submitted_on: "EBA Q&A register entry 2026_7760, field 'Submission date'" lifecycle_label: "Rejected question" --- **Question published in the EBA Q&A tool · no answer · not legislation · published 15 Jun 2026 [Rejected question]** *Rejected question · EBA Q&A register, 15 June 2026 · Checked against the EBA publication on 26 Oct 2026 · [Official source](https://www.eba.europa.eu/single-rule-book-qa/qna/view/publicId/2026_7760)* | | | |---|---| | **Full title** | EBA Q&A 2026_7760 — Q&A — Ban imposed by certain national authorities \[Rejected question\] | | **Prepared by** | Not stated in the document | | **Published by** | EBA, in the EBA Single Rulebook Q&A tool | | **Reference** | EBA_QA_2026_7760 | | **Document type** | Q&A | | **Legal nature** | No answer · not legislation | | **Addressees** | Not stated in the document | | **Dates** | Published 15 June 2026; question submitted 11 March 2026 | | **Legal basis** | PSD2 | | **Related instruments** | None recorded | | **Text on this page** | Word for word — the full text of the EBA publication | **Ban imposed by certain national authorities on the use of the term “neobank” for payment institution** ### Question Does the divergence of positions among national authorities regarding the freedom to use the term "neobank" for payment institutions not compromise the consistent application of EU law in the banking sector and the objective of convergence of supervisory practices, and does it not hinder competition and the development of cross-border activities? ### Background Differences of opinion among national competent authorities regarding the use of the term "neobank" by payment sector actors do exist. Some authorities recognize that the term "neobank" refers to new players providing payment services. For example, the Bank of Spain does not prohibit authorized entities from using the term "bank". (https://clientebancario.bde.es/pcb/es/blog/neobancos.html and FAQ: https://www.bde.es/wbe/en/punto-informacion/contenidos/advertencias-publico/las-entidades-no-autorizadas-intrusos/). Other authorities, such as the ACPR in France (ACPR Review, "Reminder of the rules for using the term 'neobank'", April 2021) and the CSSF in Luxembourg have taken a more or less direct stance against the use of the term "neobank" (specifically Rule 45 of CSSF Circular 26/906 Central Administration, Internal Governance and Risk Management addressed to all Payment Institutions and Electronic Money Institutions : “The management body shall ensure that the use of any terminology relating to services reserved for Credit Institutions, such as banking services, deposits, bank or neo-bank, bank account, etc., or to other (financial) Institutions carrying out activities not covered by Payment Institution or Electronic Money Institution licenses, is prohibited in all its forms). This situation creates legal uncertainty for Payment Institutions and Electronic Money Institutions, because the terminology used in communication is an important factor in their growth and their ability to compete with Credit Institutions. Furthermore, the ban imposed by certain national authorities constitutes an obstacle to competition and development of cross-border activities and harms the proper functioning of the internal market, which is the objective pursued by Directives (EU) 2015/2366 (PSD2) and 2009/110/EC (EMD2). Moreover, it contributes to confusion regarding how customers should understand the activities of new players and casts doubt on their reliability, which is contrary to the objective of consumer protection (Règl. (UE) n° 1093/2010, art. 9). *** ### Answer This question has not sufficiently identified a specific provision that is in a legal framework covered by this tool and that has been demonstrated to create uncertainty due to its inconsistent interpretation or application. *** **Source:** [EBA original document](https://www.eba.europa.eu/single-rule-book-qa/qna/view/publicId/2026_7760)