Regulator (KNF) Scrutinizes Limited Network Payment Instruments

A process is underway to "reauthorize" entries in the Polish Financial Supervision Authority (KNF) register of payment instrument issuers on the basis of the limited network exclusion. This process follows adoption of European Banking Authority (EBA) Guidelines on the limited network exclusion under PSD2¹. Under these Guidelines, issuers of payment instruments of this kind are required to submit the relevant notifications to regulators in each member state in which payment instruments are issued and in which the value of transactions executed over the preceding twelve months exceeds EUR 1 million.

As a rule, issuance of payment instruments (such as payment cards or mobile payment applications) is a regulated activity, and requires payment service provider status. One exception to this rule is issuing of payment instruments under the limited network exclusion specified in article 3(k) PSD2². The EBA Guidelines are intended to provide clarifications concerning the