Social Vouchers' International Association
SVIA
Social Vouchers International Association (SVIA) is an international notfor-profi t association (AISBL) established in Belgium in 2017 with the aim of promoting the social vouchers’ industry at European and international levels.
ID: 473982932097-58
Lobbying Activity
Response to Payment services – revision of EU rules (Directive)
30 Oct 2023
SVIA Contribution to the EU Commission on the PSD3 proposal The Social Vouchers International Association (SVIA) represents issuers of social vouchers, which are social benefits attributed to workers collectively by their employers, public or private, carrying a right to access specific goods or services that improve their working conditions and facilitate their work-life balance (such as access to food, culture, mobility, childcare, holidays). Social vouchers have been developed in 40 countries (19 EU Member States) over the last 50 years to facilitate the implementation of social policies and meet the needs of employers, employees, citizens, as well as public authorities. Social vouchers are therefore subject to national regulations but are also recognised by European legislation as services based on specific payment instruments excluded from the scope of the regulations on electronic money and payment services. This exclusion applies in compliance with the criteria listed in article 3k(iii) of Directive 2015/2366 (PSD2) and has been properly transposed in all Member States. SVIA welcomes the European Commission proposal for a review of PSD2, including the Payment Services Directive 3 (PSD3). SVIA specifically welcomes the continuation of the Limited Network Exemptions (LNE), which remain largely unchanged under Article 2.2.j, and in particular the social vouchers exclusion (2.2.j(iii)) of the PSR. However, a point of concern for SVIA is Article 39 of the proposed Directive, since it establishes an obligation to provide NCAs with an annual audit opinion from companies implementing activities exempted in Article 2(2), point (j) of the proposed Regulation. In the currently corresponding applicable article 37(3) within PSD2, the obligation to provide an annual audit opinion is related to the electronic communications networks exclusion, not LNE. If the intention was to retain the current status, then we believe the reference should be made to Article 2(2), point (k) as opposed to Article 2(2), point (j). But, if the European Commissions intention is to expand this obligation to LNE and the reference to Article 2(2) point (j) is correct, we dont understand why social vouchers, instruments excluded from PSD2 and introduced within article 2.2.j(iii) of the proposed PSD3, should be subject to such a procedure. SVIA would like to recall that instruments bearing characteristics listed under Article 2.2.j(iii) of PSR are social vouchers. Social vouchers are subject to national regulations but are also recognised by European legislation as services based on specific payment instruments excluded from the scope of the regulations on electronic money and payment services. This exclusion applies in compliance with the criteria listed in article 3k(iii) of Directive 2015/2366 (PSD2) and has been properly transposed in all Member States. Therefore, SVIA would recommend clarifying the intention in Article 39(2) and potentially reconsider the necessity for excluded instruments as per 2.2.j(iii) to be embed within the obligations of this article.
Read full responseResponse to Payment services – revision of EU rules (new Regulation)
30 Oct 2023
SVIA welcomes the European Commission proposal for a review of PSD2, including the new Payment Services Regulation (PSR), and the political objectives that are being pursued. SVIA specifically welcomes the continuation of the Limited Network Exemptions (LNE), which remain largely unchanged under Article 2.2.j, and in particular the social vouchers exclusion (2.2.j(iii)) of the PSR. However, we would also like to raise the attention of the Commission on the fact that the distinction between the two exemptions (with a duty to notify as under Articles 2.2.j(i) and 2.2.j(ii)) and the exclusion (without duty to notify as under 2.2.j(iii)) should be better drawn in recitals 12 and 13. SVIA recommends : - drafting a specific and independent recital for the exclusion of Social Vouchers defined in article 2.2j(iii). This will ensure consistent application of the Regulation across the EU by preventing any potential confusion for national public authorities with instruments with limited networks (referred to in Article 2.2j(i)) and very limited goods and services (referred to in Article 2.2j(ii)), notably concerning notification processes. We would welcome the reference to examples as it is currently the case in the drafting but separating those use cases per article/exemption. For instance, referring to the article 2.2j(iii) social vouchers exclusion, a possible drafting could be: o Instruments bearing characteristics listed in article 2.2j(iii) include social vouchers such as meal vouchers, mobility vouchers, childcare vouchers, holidays vouchers, ecological vouchers, or other vouchers for specific services, which are subject to a specific tax or labour legal framework designed to promote the use of such instruments. - to keep consistency with the EBA guidelines by adding the following sentence within recital 12: A single card-based or other means of payment can accommodate simultaneously more than one specific payment instrument as defined in article 2.2j."
Read full responseResponse to A new Circular Economy Action Plan
17 Jan 2020
The Social Vouchers International Association (SVIA) is an international not-for-profit association established in Belgium in 2017 with the aim of promoting the social vouchers’ industry at European and international levels. Social Vouchers, whether paper or digital, are social benefits attributed to workers collectively by their employers, public or private, carrying a right to access specific goods or services that improve their working conditions and facilitate their work-life balance (such as access to food, culture, transportation, childcare, holidays and ecological products and services…). Over the years, social vouchers have proven to be an efficient way for public authorities to incentivize the consumption of certain goods and services among citizens in order to meet specific social policy objectives.
SVIA welcomes the European Commission’s Roadmap on the new Circular Economy Action Plan. We are deeply convinced that it is necessary to move towards a more sustainable and circular EU economy, and that acting to shift mindsets towards such deep transformation should be at the core of the EU Green Deal.
More particularly, SVIA fully shares the Commission’s priority to give consumers more instruments and reliable information to make informed choice, as well as with the consideration that no one should be left behind.
SVIA strongly believes that two major levels of action should guide future Commission initiatives, including: to change consumers’ mindsets (through more education, government programs to orientate consumers towards circular products, and better information), and the need to keep the prices of sustainable and circular economy goods affordable.
In this regard, SVIA would like to shed some light on the eco-voucher, an innovative practice developed in Belgium 10 years ago and which delivers on those objectives. The eco-voucher was created by Belgian social partners and has since proven to be an efficient tool to change consumers’ mindsets towards a more sustainable consumption. The eco-voucher as it exists in Belgium is delivered to employees by their employer (at 0 upfront cost for the state) for up to 250€/year and is exempted from social and company taxes. Employees can spend their eco-vouchers in a network of merchants only for ecological goods and services. The list of those accessible goods and services includes 3 categories: ecological products and services with an EU ecological label, sustainable mobility and leisure, and circular economy products: waste, re-use and recycling products.
Over the years, the eco-voucher has proven its efficiency in changing consumers’ mindset by orientating their consumption towards sustainable products and services through this incentive which makes their decision to buy ecological more affordable. A recent study published by the University of Hasselt and Indiville cvba has shown that half (54%) of Belgian workers who benefit from eco-vouchers claim they take ecological considerations when making a purchase. This figure has considerably increased compared to 2017 (39%), which demonstrates a clear impact of the program in just 2 years.
Therefore, as part of its future initiatives to empower consumers to contribute to the circular economy, SVIA invites the EU Commission to promote the emergence of eco-voucher systems (adapted to national contexts) in Member States.
We attach to this response an Infographic which present the Eco-voucher program in Belgium and its main impacts. Additional information on the eco-voucher can also be found on the dedicated page of the European Circular Economy Stakeholder Platform.
Read full response