The law is very clear on this. Article 81 of Directive (EU) 2015/2366 on payment services in the internal market (PSD2) states:
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Member States shall require the payment service provider(s) of the payer, the payment service provider(s) of the payee and any intermediaries of the payment service providers to transfer the full amount of the payment transaction and refrain from deducting charges from the amount transferred.
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However, the payee and the payment service provider may agree that the relevant payment service provider deduct its charges from the amount transferred before crediting it to the payee. In such a case, the full amount of the payment transaction and charges shall be separated in the information given to the payee.
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If any charges other than those referred to in paragraph 2 are deducted from the amount transferred, the payment service provider of the payer shall ensure that the payee receives the full amount of the payment transaction initiated by the payer. Where the payment transaction is initiated by or through the payee, the payment service provider of the payee shall ensure that the full amount of the payment transaction is received by the payee.
EU directives are not law; they need to be enacted into national law in each EEA member state. Revolut is based in the United Kingdom. The above Article 81 is enacted into UK law under Regulation 84 of the Payment Services Regulations 2017, which states:
(1) Subject to paragraph (2), the payment service providers of the payer and payee must ensure that the full amount of the payment transaction is transferred and that no charges are deducted from the amount transferred.
(2) The payee and its payment service provider may agree for the relevant payment service provider to deduct its charges from the amount transferred before crediting it to the payee provided that the full amount of the payment transaction and the amount of the charges are clearly stated in the information provided to the payee.
(3) If charges other than those provided for by paragraph (2) are deducted from the amount transferredā
(a) in the case of a payment transaction initiated by the payer, the payerās payment service provider must ensure that the payee receives the full amount of the payment transaction;
(b) in the case of a payment transaction initiated by the payee, the payeeās payment service provider must ensure that the payee receives the full amount of the payment transaction.
It is clear that Revolut, as the payment service provider of the payer, āmust ensure that the full amount of the payment transaction is transferred and that no charges are deducted from the amount transferredā. It is Revolutās responsibility to ensure that its intermediary banks (including its chosen bank Lloyds) do not deduct fees, in order to ensure Revolutās compliance with the legislation. If fees are deducted, then there is a remedy under Regulation 84(3)(a) of the Payment Services Regulations 2017, requiring Revolut to āensure that the payee receives the full amount of the payment transactionā. If an intermediary bank has deducted charges, then you should insist to Revolut that it complies with Regulation 84(3)(a) and resends any shortfall amount. If Revolutās support people refuse to comply, then you should complain via Revolutās formal complaint process, quoting the above legislation.
If Revolut cannot prevent fees from being charged by its intermediary banks, then Revolut would need to advertise a charge for bank transfers in order to cover these costs. What Revolut canāt do is advertise that it doesnāt charge for bank transfers and then allow fees to be unlawfully deducted by intermediary banks from the amount transferred. Schedule 1 Paragraph 20 of the Consumer Protection from Unfair Trading Regulations 2008 states that the following is an unfair commercial practice:
Describing a product as āgratisā, āfreeā, āwithout chargeā or similar if the consumer has to pay anything other than the unavoidable cost of responding to the commercial practice and collecting or paying for delivery of the item.
Furthermore Regulation 5(4)(g) of the Consumer Protection from Unfair Trading Regulations 2008 prohibits a misleading indication of price.