There can be a lot of confusion about the ‘mobile wallet’ and its regulatory implications.
To help clarify the regulatory implications of a mobile wallet, the analogy with a traditional leather wallet can be helpful. A leather wallet has no regulatory implication per se. It is just a container for different payment instruments, such as cash and cards. This is also true for the mobile wallet. The mobile wallet is just a menu on the phone, which provides access to different payment instruments. The payment instruments are regulated as opposed to the wallet.
The equivalent to cash in the leather wallet is e-money in the mobile wallet. E-money is either regulated by e-money regulation or by traditional banking regulation. If there is no e-money regulation, then the e-money can only be held in a bank account held by a bank. If there is e-money regulation, the mobile operator can hold the prepaid cash of its customers in a secured float. In this case the customer can store money in a prepaid account in the wallet, i.e. the mobile operator can offer the customer the ability to store money in the mobile wallet.
The equivalent of a credit or debit card in the wallet is the option to choose a card provider. The customer effectively uses a card processing provider and the payment is processed in a similar way as a traditional card payment. As in the real world, it is the card payment processor who is responsible for regulatory compliance.
