Last week I was present at the first part of a GTIAD-meeting on the applicability of the Electronic Money Directive (and the local legislation that implements the directive) for mobile telecom operators. At the meeting, the telecom operators acknowledged that what they were doing constituted electronic money (depending on the organisational setup of their business). In line with this reality other industry representatives stated that consequently, all e-money issuers should be subject to the same rules.
The next steps in the process will be that the GTIAD will make up its mind on this subject and send an advice to the Banking Advisory Council. Then, a consultation may take place on how to further proceed and make sure that the legislation will be applied in a proportional and adequate way to the telecom organisations.
See also the article in todays Volkskrant (registration required).