“Which?”, the UK consumer magazine, has published an article today about Ryanair’s particularly underhand implementation of dynamic currency conversion. The article is written in a very UK-centric way, incorrectly assuming that all UK-issued cards are denominated in GBP, which overlooks the existence of Revolut and other UK-issued multi-currency and non-GBP cards. Nevertheless the article is rightly critical of Ryanair.
This quote from Ryanair is particularly irritating:
‘Customers have the option of paying in the currency of their payment card which gives absolute certainty of the final payment amount.’
I understand that it’s impossible for a merchant to identify the currency of a payment card and that a merchant can identify only the country of issue (based on the BIN). Disingenuous merchants such as Ryanair then make a very flawed assumption that the card is denominated in the national currency of the country of issue.
I question whether Ryanair is breaching Article 5(1) of Regulation (EU) 2018/302, which states:
A trader shall not, within the range of means of payment accepted by the trader, apply, for reasons related to a customer’s nationality, place of residence or place of establishment, the location of the payment account, the place of establishment of the payment service provider or the place of issue of the payment instrument within the Union, different conditions for a payment transaction
Ryanair would probably argue that it is not applying “different conditions”, because a customer can opt out of DCC, but I would argue that Ryanair, by coercing customers into DCC by default and making the opt-out so difficult to find, Ryanair is in fact applying “different conditions”.
“Which?” goes on to say:
We have raised our concerns with the Civil Aviation Authority (CAA) because of the manner in which Ryanair presents the rate to customers. It could be misleading and in breach of consumer protection legislation.