EBU Single Rulebook Q&A 28 June 2018 2018_4030 Geographical scope of application of the RTS on strong customer authentication (SCA) and secure communication requirements – ‘Two-leg’ transactions

Is it necessary that issuer, acquirer, cardholder and merchant be all located in the EEA for the RTS on SCA requirements to apply to two-leg transactions?May the issuer use the merchant’s location as a proxy (in lieu of the acquirer’s location)? The PSD2 applies to payment transactions where both the issuer and the acquirer are located within the EEA (‘two-leg’ transactions).