European bank experts seek clarification on e-money definition plus related fraud reporting requirements

The European Banking Authority’s Guidelines on Fraud Reporting under PSD2 require banks and other payment service providers (PSPs) to distinctly report fraudulent e-money payment transactions to their national competent authorities, but they do not specify in detail which transactions fall under the e-money definition from the 2009 E-money Directive they refer to.

The note was created to reflect the discussions and findings of a workshop series on the EBA Fraud Reporting Guidelines that the Euro Banking Association organised in 2019 at the request of participants in the PSD2 Practitioners’ Panel and the SCT Inst Migration Action Round Table (SMART2), which are two payment expert groups hosted by the Association. The requirements of these Guidelines have or will become applicable to PSPs across Europe, depending on the timings decided by their respective national competent authority; the varying timings lie between late 2018 and 2021.

On more than one topic, the bank experts in the EBA-run workshops came to the same conclusions as the European Commission in its 2018 report on the E-money Directive. The resulting note, “How to report e-money transactions under the EBA Fraud Reporting Guidelines,” issued by the PSD2 Practitioners’ Panel and SMART2 is available for download from the Euro Baking Association’s website.

It is the second note that was issued as a result of the above-mentioned workshop series. A first note calling for more fraud reporting consolidation and harmonisation across Europe was issued in April 2019.