Question
Is providing payment service via Internet banking (web-application) payment initiation channel considered to be issuing of payment instruments?
Background on the question
PSD2 Directive sets list of payment services, among which according to Annex 5. Issuing of payment instruments and/or acquiring of payment transactions. Payment instrument is defined as a personalised device(s) and/or set of procedures agreed between the payment service user and the payment service provider and used in order to initiate a payment order according to Article 4 (14). Does the use of web-application (so-called internet-banking) or mobile application for providing other payment services (e.g. defined in Annex 1 p. 3 (a-c) and 4(a-c)) requires authorisation for service p.5 Issuing of payment instruments and/or acquiring of payment transactions?