EBU Single Rulebook Q&A 26 January 2017 2017_3129 Outflows associated with Payment Institutions' escrow accounts

Can the escrow accounts held for Payment Institutions be considered as operational deposits ? Payment Institutions are legally required to transfer the funds they receive to dedicated escrow accounts. These accounts are generally held in the books of Credit Institutions and mirror the deposits collected by the Payment Institutions. Payment Institutions cannot withdraw these funds freely.