Bank of Lithuania approved the application of the PSD2 limited network exclusion to “Gera dovana”

The PSD2 has narrowed the scope of the limited network exclusion resulting that many business models could require the payment services provider licence. It was a case with our client, UAB “Gera dovana”, Lithuania’s major gift cards and vouchers administrator.

We have helped the client to get approval from the Bank of Lithuania that “Gera dovana” can rely on limited network exclusion and administer shopping mall gift cards and vouchers without having payment services provider licence.

We have furnished the Bank of Lithuania with detailed explanations of activities carried out by “Gera dovana,” as well as descriptions of the cards/vouchers/sets, explaining how they function and outlining the limitations and specificities of their use. Consequently, the Bank of Lithuania, after evaluating all the submitted information on the payment instruments issued by “Gera dovana” (gift cards and gift vouchers), recognized that these services comply with the criteria of the limited network exclusion and included these products in the official register.

Even though the PSD2 should have harmonised the payment market regulations across the EU, the positions of the national competent authorities in EU member states regarding the scope of the limited network exclusion vary significantly.

“Gera dovana” also acts in Latvian, Polish and Chech Republic markets and seeks that the application of the limited network exclusion would be recognised in these countries as well.