ELM 6.10.1 R does not:
The rules in this chapter make various distinctions about e-money. For example, they distinguish between e-money issued by the firm and e-money issued by other e-money issuers. With some e-money schemes it may not be possible for a firm to make those distinctions. If this is the case, ELM 6.10.1 R ensures that the rules in this chapter still apply.
Thus, for example, if a firm is unable to distinguish between: