Following the EU Council’s approval of the Instant Payments (IP) Regulation in mid-February, its publication in the Official Journal of the EU was merely considered a “formality”. For the banks affected by the legislation, this date could have been a little further in the future, but the hoped-for “postponement” failed to materialise, and the IP legislation was now published in the Official Journal of the EU on 19 March 2024:: Regulation – EU – 2024/886 – EN – EUR-Lex (europa.eu)

This is an important milestone for the implementation timetable, not least because the implementation period for the introduction of instant payments officially begins 20 days after publication of the law in the EU Official Journal.

The period begins to run

Briefly in figures: The receipt of Instant Payments must therefore be ensured from 8 January 2025, while the sending of Instant Payments and the much-discussed Verification of Payee (VoP forshort) )must be ensured 08.10.2025 by 8 October 2025.. Thismeans that there is now a clear timeline for all financial institutions’ IP projects.

This development was reason enough for us at Gravning to look at IP regulation again on 28 February 2024 as part of our successful Expedition format. In addition to representatives from the banking sector (Aareal Bank, Deutsche Apotheker- und Ärztebank, Berenberg, Santander), we were also able to attract representatives from the provider environment (Geva, PPI, van den Berg) for our Expedition and discuss the challenges of regulation in two exciting panels.

The topicality of the subject was also emphasised by more than 70 interested guests from the financial sector.

The quintessence of the discussions was clear:

Yes, we are all pleased that the Instant Payments Act has now been finalised and that numerous questions have already been clarified based on the legal text and details have been included in the final version during the legislative process.

Nevertheless, many questions remain unanswered. Some of the content has not (yet) been sufficiently analysed, while others have not been formulated precisely enough and offer room for speculation, which leads to further questions.

To begin with, here is just a selection of the issues that concern numerous companies:

  • How exactly will sanction screening against non-EU lists have to be regulated in future?
  • Will the existing transaction limit of €100 thousand fall and what impact will this have on my systems?
  • How can 24/7/365 credit management be ensured?
  • Will there be adjustments to the liquidity management functions in future (keyword TARGET accounts)?
  • How exactly should interest offsetting be handled in future?
  • How exactly will the Verification of Payee (VoP) be designed and implemented for the various customer access channels?

A number of questions therefore remain that will require financial institutions to continue to monitor developments closely.

A first step in the specification of the Verification of Payee has nowbeen taken.

A first draft of a future rulebook and corresponding matching rules was published by the EPC in mid-February (Public consultation on the Verification Of Payee Scheme Rulebook | European Payments Council).

A public consultation on this draft will take place until 19 May 2024. All stakeholders are invited to participate in this process.

The public consultation will be evaluated between the end of May and August 2024, at the end of which a significantly revised version of the Rulebook will certainly be published. According to the current schedule, a final version of the Rulebook will be published by the EPC at the end of September 2024. This means that the Rulebook will enter into force in time for the implementation of the VoP by October 2025.

Offer for exchange

We at Gravning are currently working intensively on the IP legislation and the published draft rulebook on VoP and want to offer all interested banks and financial institutions the opportunity to exchange ideas in a protected environment in the future to be able to discuss any issues relating to Instant Payments with other bank representatives.

We want to set up an IP exchange for this in the future – if you are also interested in this exchange, please get in touch with us at events@gravning.de. Participation is free of charge and without obligation.

If you also need support in implementing the requirements of the IP Act, please feel free to contact us at any time at office@gravning.de – with our expertise from various instant payments projects, we will be happy to support you in the successful implementation within the ambitious schedule.

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