Since October 2022 at the latest, it has been clear that the obligation for banks to offer Instant Payments is coming!

The EU Commission has made this clear with its draft legislation. Since that time, there has been a significant amount of discourse and disagreement regarding this draft in the payments’ industry, involving banks, payment service providers, consultants, and other stakeholders. The core elements have been carefully considered and have been approved or rejected, some more than others.

But what has happened since the initial draft bill was submitted? Are there any further or new findings? What are the real challenges facing banks and financial institutions today?

After the initial news of a coming obligation to introduce Instant Payments was digested, many financial institutions first took a ‘pay attention’ position. This topic is being closely followed by the various houses, but there are still certain uncertainties as to when and how Instant Payments will have to be offered in the future. How will the IBAN-Name-Check be conducted, and how will compliance checks for real-time payments take place in the future?

The institutions that have yet to implement Instant Payments, and there are currently approximately 160 German institutions, are increasingly pressured to commence their implementation or at the very least, plan their implementation in a timely manner. Furthermore, there exist numerous other institutions that have already implemented Instant Payments or are currently restricted to receiving Instant Payments (IP Passive). Due to the impending legal requirements, these institutions are also faced with the need to implement additional issues or topics that have not yet been considered. This has a negative impact on project runtimes, budget planning, and the availability of the relevant specialist staff. Even institutions that can already receive and send instant payments will have to adapt their painstakingly established processes again and set up corresponding follow-up projects. This is because the requirement for the verification of the IBAN and Name of the payee (IBAN-Name-Check) or, alternatively, the modification of the screening of the sanctions list was only revealed in the draft law.

Considering this background, all financial institutions must act again after the law has been passed, some more than others. Regardless, each institution will have to overcome the corresponding challenges.

Further, a revised draft law of the EU Council was published on 12/05/2023, which again presents the potential law in more detail.

Since the implementation deadlines for the introduction of reachability for real-time payments have now been increased to 12 and 24 months, respectively, for the dispatch of real-time payments. This provides a little more breathing space for the implementation projects of the respective houses; however, it is still not a reason to feel a sigh of relief.



  1. Transfer orders can also be submitted in non-electronic form as instant payments. In these instances, the acknowledgment of the payment order is defined as the moment at which it was converted into an electronic format.
  2. The IBAN-Name-Check will be optional for non-consumers and will be able to be issued or activated as required. The utilization of this service ought to be provided at no cost to consumers and should be able to be billed for non-consumers.
  3. Foreign currency accounts can also order instant payments in Euros. Accordingly, the time of receipt of the payment order shall be the time when the foreign currency is converted into Euro.
  4. Upon receipt of the payment, the payment service provider of the payment initiator must notify the payment initiator within 10 seconds of the failure to execute the payment. Consequently, all payment orders must be processed within a few seconds.

The main focus here is clearly on point 4, which could have the greatest impact and could pose massive challenges for financial institutions.

The notification of the (non) successful execution of the real-time payment order to the payment initiator within a timeframe of 10 seconds following receipt of the payment. This presents a significant obstacle for all processes and IT systems, not only for the houses themselves. The payment providers are also potentially affected. All systems must not only possess fail-safe features but also operate efficiently. All interfaces will also need to be tested once more to meet the time constraints.

Furthermore, there will be sanctions in the future if violations of the law are discovered. This will increase the pressure on the institutions to comply with all the requirements within the set timeframe. In addition, there are other issues that have not been considered in the considerations to date, beyond the implementation projects or challenges arising from the draft law. For instance, the proper interest settlement for instant payments is a matter that will require the institutions to consider.

These comments demonstrate that all institutions will be greatly impacted by the law and will face several challenges that must be addressed.

Gravning has been supporting our customers for years with various projects for the implementation of Instant Payments. We have extensive technical, market, and provider knowledge without ignoring regulatory requirements. Furthermore, we have developed an ‘Instant Payments Quick Check’ for our customers, which we have already been able to conduct at various institutions or are currently still actively conducting.

With our ‘Instant Payments Quick Check’, we can answer the question of how big their challenges are in implementing Instant Payments. We can quickly help you identify and prioritize your institution’s key action areas for successful implementation of Instant Payments.


  • Detailed consideration of specific challenges based on sound experience from both Instant Payments implementation projects and Quick Checks that have already been run and successfully completed.
  • A valid implementation recommendation for Instant Payments which is based on extensive industry and market knowledge, as well as from implementation projects at various banks.
  • The decision on the selection of a suitable Payment service provider or system (existing or new) for the introduction of Instant Payments.
  • A sound implementation strategy that is essential for the implementation of Instant Payments, which is feasible following the Quick Check process.

The Gravning ‘Instant Payments Quick Check’ could be the link between the regulatory requirements of the EU Commission and a successful Instant Payments implementation in your organization.

If you have any questions or are interested in a joint exchange, please do not hesitate to contact us. We are delighted to collaborate with you on the forthcoming challenges in the context of the Instant Payments commitment!

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