Hungary: Electronic Money
Electronic money is very often distributed and redeemed in small kiosks, petrol stations and shops. However, the nature of the legal relationship between the shop/kiosk owner and the electronic money issuer or electronic money distributor is not always clear.
The EMD2 Directive which regulates the provision of electronic money issuance only distinguishes between electronic money issuers and distributors. It requires member states to allow electronic money issuers to distribute and redeem electronic money through natural or legal persons who act on their behalf. While the EMD2 Directive does not provide any details on the nature of the relationship between the electronic money issuer and the distributor, nor does it exclude the possibility for an e-money distributor to have a subcontractor, the relevant Hungarian act on e-money issuers contains ambiguous provisions on this matter.
To the question of whether an e-money distributor could use legal or natural person subcontractors for the distribution or redemption, the National Bank of Hungary provided a clear answer this year. It stated that e-money distributors are not allowed to use subcontractors. Though the reasoning that the authority made raises serious questions (i.e. one may not do what is not allowed explicitly in a legal act even if it is not forbidden either), it is currently clear that in Hungary, e-money distributors could only perform their activities themselves with their employees. The opinion of the National Bank of Hungary has had significant effects on the market.
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