MEP David Casa (PPE) has raised concerns that a European Banking Authority (EBA) Q&A on the definition of electronic money could disrupt four-party payment schemes, such as those involving card networks. In a parliamentary question submitted on 30 June 2026, Casa asks the European Commission whether the interpretation in Q&A 2022_6336 is compatible with the E-Money Directive and whether the Commission will clarify that e-money products operating through four-party schemes are not covered by the Q&A.
The question targets the EBA's Q&A 2022_6336, published on 17 January 2025 and authored by the Commission, which addresses the contractual relationship between e-money issuers and merchants. Casa argues that the Q&A's narrow interpretation of the transfer of e-money to merchants may not account for how four-party payment schemes function, potentially preventing such products from operating. The MEP's query directly challenges the Commission's stance, seeking assurances that the Q&A will not inadvertently restrict legitimate e-money products.
first, for the Commission to explain how the Q&A's interpretation aligns with the E-Money Directive and relevant case law; second, for a commitment to clarify that four-party scheme e-money products fall outside the Q&A's scope. The question signals a policy orientation favouring a broader, more flexible interpretation of e-money rules to accommodate existing market practices, particularly those involving multiple parties like card networks.
The Commission is expected to reply within approximately six weeks. Its answer will indicate whether it intends to maintain the current interpretation or issue further guidance, potentially impacting e-money issuers, merchants, and payment scheme operators. The outcome could affect the regulatory clarity for four-party payment models, a key concern for the fintech and payments industry. The question also highlights tensions between preserving regulatory consistency and adapting to market realities, with implications for innovation and competition in digital payments.