We issue a prepaid card that is used only in brand X's stores. Does this fall within the scope of electronic money issuance?
A prepaid card used only in brand X's stores is considered to be used “only within a limited network of service providers” and to be outside the scope of the Law under the fifth paragraph of Article 18 of the Law. However, the assessment of each business model against the fifth paragraph of Article 18 of the Law must be made separately, taking into account the principles of how that business model operates.
Gift card and loyalty card examples
This exemption is most often seen with gift cards that are accepted in the stores of a single brand. As long as the card is used only within the issuing brand or a clearly defined limited network, it is considered out of scope.
Features such as the card also being accepted by other brands or in the general POS network, allowing cash withdrawals, or allowing transfers between cards may remove the exemption.
Marketing teams should carry out an assessment with the legal and compliance team when adding new features.
