RD195 - ETNO Reflection Document on the European Commission Consultation Paper on the application of the E-money Directive to mobile operators

The tentative conclusion that "e-value stored on mobile phone pre-paid cards that is used to pay third party products and services is indeed likely to be e-money" seriously concerns ETNO members, many of which have leading European mobile affiliates.

Only 2-4% of the pre-paid financial volume is used for third party payment services. Applying E-money Directive regulation to the whole account and handling it through a subsidiary company would be disproportionate, very burdensome for undertakings whose core business is unrelated to the issuance of e-money, and would endanger the system’s current simplicity and user-friendliness. ETNO wishes to see a list of criteria to determine which types of activity fall under the scope of the E-money Directive and recommends that the Directive be revised as soon as possible to take into account the evolution of technologies and businesses that will allow the development of new digital content and services.