In position RS2026-08, the Czech National Bank clarified the boundary between a currency exchange transaction and a payment service. For exchange-office operators, the key questions are where and how the customer makes the payment and how the exchanged funds are delivered.
When card payments are permitted
A bureau de change may accept a card payment under its existing authorisation if:
the customer initiates the payment on a terminal located at the exchange-office premises;
the payment is made in one currency; and
the operator pays out cash, or issues a cheque, in another currency.
This is a currency exchange transaction under Section 2(1)(b) of the Currency Exchange Act.
When the exchange authorisation is not enough
The following fall outside this regime:
card payments through an online payment gateway;
bank transfers, including payments initiated using a QR code;
payments through PayPal or a similar service; and
crediting the exchanged funds to the payment account linked to the customer’s card.
These are non-cash foreign-exchange transactions and therefore payment services under the Payment System Act. The provider must hold the appropriate authorisation.
Practical impact
These models are not necessarily prohibited, but they cannot be provided solely under a bureau-de-change authorisation. Before launching the service, the operator should review the actual flow of funds, the technical setup and the regulatory status of all providers involved.
Source: CNB position RS2026-08, published on 2 July 2026.
The English names “Currency Exchange Act” and “Payment System Act” follow the terminology used on the CNB’s English-language website.
Do you offer card payments, online currency exchange or payouts to an account? We will review whether your model falls within your authorisation and complies with the Payment System Act.
