Pursuant to Section 1 para. 1 sentence 2 no. 3b of the German Payment Services Supervision Act (ZAG), the term “payment card business” refers to the execution of payment transactions through a payment card or similar payment instrument. It is very difficult to distinguish “payment card business” from the issue of payment instruments (Section 1 para. 1 sentence 2 no. 5 1st alternative ZAG).