EBU Single Rulebook Q&A 12 April 2022 2022_6421 EMI's application of negative interest rates to its clients

Is an electronic money institution (EMI) allowed to apply negative interest rates to its clients (electronic money holders)? Article 12 of the E-Money Directive (2009/110/EC) (hereinafter referred to as the Directive) only bans the granting of interest and those other benefits which are related "to the length of time during which the electronic money holder holds electronic money", as stated in