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  • Julien Haye

Understanding E-Money Distributor and Payment Initiation Services

Understanding E-Money Distributor  and Payment Initiation Services

In the modern financial services landscape, the roles of E-Money Distributors (EMDs) and Payment Initiation Services (PIS) have become increasingly prominent, especially with the rise of fintech and digital banking. Both play unique roles in the digital payment ecosystem and are subject to specific regulatory requirements. This article provides an in-depth look at EMDs and PIS, their functions, registration processes, and their impact on the financial services industry.

E-Money Distributors (EMDs)


Function of EMDs:


  • EMDs are entities that distribute or redeem electronic money (e-money) on behalf of an Electronic Money Institution (EMI). They do not issue e-money themselves but act as intermediaries between EMIs and customers.

  • Their role includes facilitating the use of e-money products, such as prepaid cards or digital wallets, provided by a licensed EMI.


Registration and Compliance:


  • EMDs must register with the financial regulatory body in their jurisdiction, such as the Financial Conduct Authority (FCA) in the UK.

  • They must comply with relevant regulations, particularly in areas like anti-money laundering (AML) and know your customer (KYC) standards.


Examples of EMD Activities:


  • Selling or distributing prepaid cards to consumers or businesses.

  • Facilitating top-ups of e-money accounts or wallets.

  • Assisting in the redemption of e-money for cash or other forms of payment.


Examples of E-Money Distributors


  1. Revolut: Though primarily known as a fintech company offering a range of financial services, Revolut also acts as an EMD by distributing e-money through its digital banking platform. Users can top up their Revolut accounts, which is essentially storing e-money for future transactions.

  2. Prepaid Card Companies: Many companies offer prepaid cards that are loaded with e-money for various uses, such as travel or gift cards. An example is the Post Office in the UK, which offers a Travel Money Card – a prepaid card that users can top up in various currencies.

  3. Retail Chains: Some retail chains partner with EMIs to offer branded prepaid cards or e-money solutions. For instance, a supermarket chain might offer a prepaid card that can be topped up at checkout and used for future purchases in-store or online.

  4. Mobile Wallet Providers: Companies like Google Pay or Apple Pay can be considered EMDs when they facilitate the storage and use of e-money through their digital wallet services, even though the actual e-money is issued by partner banks or financial institutions.

Payment Initiation Services (PIS)


Function of PIS:


  • PIS are services that initiate a payment order at the request of a consumer from their bank account to a third party. These services are a part of the open banking ecosystem, providing an alternative to traditional payment methods like credit cards or bank transfers.

  • PIS providers facilitate transactions directly between bank accounts, often enabling faster and potentially cheaper payments.


Registration and Regulatory Framework:


  • Similar to EMDs, PIS providers must register with a relevant regulatory authority.

  • They are subject to stringent regulations regarding data protection, customer consent, and secure transaction processing.

  • PIS providers must ensure robust cybersecurity measures to safeguard customer data and transaction details.


Examples of PIS Activities:


  • Enabling e-commerce purchases directly from a customer’s bank account.

  • Facilitating bill payments directly from a user’s bank account without the need for credit/debit cards.

  • Offering an interface for consumers to manage and initiate various payments across different bank accounts.


Examples of Payment Initiation Services


  1. Klarna: Known for its "buy now, pay later" service, Klarna also offers direct payment options that allow users to pay for online purchases directly from their bank accounts, bypassing traditional card payments.

  2. Trustly: Trustly is a European payment service provider that specializes in direct bank payments. Users can make online purchases or fund online accounts directly from their bank accounts using Trustly’s service, without needing a credit or debit card.

  3. PayPal: While primarily known for its e-wallet service, PayPal also offers features that could be classified under PIS. For example, users can make online purchases or send money to others directly from their linked bank accounts.

  4. GoCardless: This is a UK-based company that specializes in direct debit services. GoCardless allows businesses to collect payments directly from their customers’ bank accounts, which is particularly useful for recurring payments.

Impact on Financial Services


  1. Enhanced Consumer Convenience: Both EMDs and PIS offer consumers more options for managing their finances and making payments, often with greater convenience and efficiency.

  2. Fostering Innovation: These services are at the forefront of fintech innovation, challenging traditional banking models and offering new pathways for financial transactions.

  3. Supporting Financial Inclusion: EMDs and PIS can play a role in financial inclusion by providing alternative financial services to those who may not have full access to traditional banking.

  4. Data Security and Trust: Given the digital nature of these services, maintaining high standards of data security and earning consumer trust are paramount for EMDs and PIS providers.


The roles of E-Money Distributors and Payment Initiation Services are integral to the evolving digital financial landscape. As fintech continues to grow and reshape the way we interact with financial services, understanding the functions, regulatory requirements, and potential impacts of EMDs and PIS becomes increasingly important. For businesses in the financial sector, leveraging these services can lead to more efficient operations and enhanced customer experiences, while for consumers, they offer more control, flexibility, and options in managing their finances.


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