FCE’s views primarily relate to the issues identified in the report around the Limited Network
Exclusion (“LNE”) in PSD2 and, in particular, the idea of setting a certain threshold for the
volume of payment transactions above which a firm can no longer benefit from the exclusion
and must therefore be authorised. FCE is concerned about the implications of introducing such a threshold, which would effectively bring fuel cards under the scope of PSD2.
FCE members believe that fuel cards should be out of scope of PSD2 entirely. However, we are aware of the exemptions articulated in the framework and currently make use of
the LNE regime under Article 3 (k) (ii).
Our paper outlines why a threshold for the volume of payment transactions should not be introduced for fuel cards as well as emphasising the need for a harmonised approach to LNE notifications under PSD2.