Payment knowledge pays off

Assistance for correct classification

What is e-money and what are the special features?

We'll tell you!
Vouchers are a good alternative to gifts in kind for many consumers, but the issuing traders also benefit from the sale: voucher cards have been proven to increase sales. However, caution is advised when issuing vouchers: as a trader or trader association, you quickly find yourself with your voucher system in the area of electronic money (e-money), for which a permit from BaFin is required.
E-Geld-Bereichsausnahmen

What is e-money?

According to § 1 para. 3 of the Payment Services Supervision Act (Zahlungsdiensteaufsichtsgesetz - ZAG), e-money is any electronically stored monetary value in the form of a claim on the issuer, which is issued against payment of an amount of money, in order to carry out payment transactions with it and which is also accepted by persons other than the issuer.

In simple terms, the following e-money guidelines must be met:

  1. It is a monetary value stored on an electronic device or remotely on a server.
  2. E-money must be accepted as a means of payment by at least one entity other than the issuing entity.
  3. The value is issued against payment of a "real" amount of money. It does not matter whether the payment is settled in cash or not.

E-money is issued by e-money institutions, which must comply with certain due diligence requirements. For example, new customers must undergo a legitimation check.

What are the exceptions?

§ 2 para. 1 no. 10 and no. 11 of the ZAG list exceptions that are clearly distinguished from e-money. Accordingly, it is no longer electronic money as soon as

  1. monetary values only for acquisition within a limited trader network
  2. can be used for a limited range of services or goods, or
  3. a social and fiscal purpose is achieved.
Limited network

If the customer can only use the voucher or gift cards of a store chain in its shops. The prerequisite is a uniform market presence (use of a uniform payment brand). In addition, the product may only be redeemed in Germany - and accordingly only in the German branches of the store chain.

Limited range of goods or services

If the customer can only redeem the voucher or gift card for a specific product group - for example, so-called beauty cards for the purchase of perfume, cosmetics and skin and hair care products.

Whether an exception applies can only be clarified with legal certainty by an enquiry to BaFin

Use cases for card programmes

Card programme

Framework conditions

E-money status

Card programme
Centre voucher

A voucher solution for shopping centres. The centre voucher can only be redeemed in the shopping centre - but there at every participating retailer located in the centre (regardless of their product range).

Framework conditions
  • YES: electronically stored monetary value
  • YES: value must be available for payment to at least one person or entity other than the issuer.
  • YES: issued against payment of a sum of money
  • YES: use only within a limited network
E-money status

It is not e-money within the meaning of the ZAG

Card programme
eWallet for cross-centre parking

An electronic credit card that can be used at any centre to pay parking fees - and only to pay them.

Framework conditions
  • YES: electronically stored monetary value
  • YES: value must be available for payment to at least one person or entity other than the issuer.
  • YES: issued against payment of a sum of money
  • YES: use only possible for a limited range of services
E-money status

It is not e-money within the meaning of the ZAG

Card programme
Retailer chain voucher

A voucher solution for retailers with and in the branch system (H&M, ECE, New Yorker): the voucher card can be redeemed in any branch of the branch network within Germany.

Framework conditions
  • YES: electronically stored monetary value
  • YES: value must be available for payment to at least one person or entity other than the issuer.
  • YES: issued against payment of a sum of money
  • NO: use only possible for a limited range of services
  • NO: use only within a limited network
E-money status

Attention! This is e-money within the meaning of the ZAG

Card programme
Non-cash remuneration voucher

A voucher solution for retailers with and in the branch system (H&M, ECE, New Yorker): the voucher card can be redeemed within a branch of the branch network.

Mehr dazu

Framework conditions
  • YES: electronically stored monetary value
  • YES: value must be available for payment to at least one person or entity other than the issuer.
  • YES: issued against payment of a sum of money
  • YES: use only possible for a limited range of services
  • YES: use only within a limited network
E-money status

It is not e-money within the meaning of the ZAG

Card programme
Cross-centre bonus programme
Framework conditions
  • YES: electronically stored monetary value
  • YES: value must be available for payment to at least one person or entity other than the issuer.
  • NO: issued against payment of a sum of money
E-money status

Attention! This is e-money within the meaning of the ZAG

Summary
Whether a merchant needs a BaFin permit for issuing vouchers or gift cards, is subject to notification or has no ZAG obligations at all depends on the individual case. The answers to questions such as "Who will accept my voucher?" or "Which products are available with my gift card?" are decisive. Issuers of vouchers should therefore always keep the issue of ZAG in mind when specifically designing vouchers and gift cards.
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