Is it permissible to purchase a gift voucher or a gift card cheaper than it’s value? E.g purchase a £100 value amazon gift card discounted at £80?
I have came across this FCA document which defines the regulation of “e-money” and gift cards are covered under the scope of “e-money” as stated below.
2.5 E-money is not strictly a surrogate for cash. Nor are prepaid cards a direct substitute for
debit or credit cards. E-money works best when it facilitates new solutions to existing problems.
This is, first, because e-money has its own cost and revenue structures, depending on different
business models; and secondly, because customers tend to switch away from existing payment
methods only when e-money offers a better way to make a payment. The most successful emoney applications have been those that have solved specific problems. Examples include
pathbreaking ways to make internet payments; send and receive money on-line; a host of
prepaid card applications such as gift cards and travel money cards; and nascent mobile phone
However, in the same document at page 55, there are some exclusions to e-money
Electronic money: exclusions
3. For the purposes of these Regulations electronic money does not include—
(a) monetary value stored on instruments that can be used to acquire goods or services
(i) in or on the electronic money issuer’s premises; or
(ii) under a commercial agreement with the electronic money issuer, either within a
limited network of service providers or for a limited range of goods or services;
Based on above exclusions, my understanding is that “store specific” or “limited network” gift cards that are used to purchase goods only does not fall under FCA’s definition of e-money. Furthermore, most store specific gift cards in UK have an expiry date (typically two years) and cannot be exchanged for cash which differentiates them from actual money.