EPC Q1 2026 Payments Reports Roundup: What Matters for EU Payment Firms

ByOfficer

Last updated: April 2026

On 21 April 2026, the European Payments Council published its quarterly “Around the Web” compilation, rounding up seven reports on payments published during Q1 2026. These EPC Q1 2026 payments reports span global payment trends, ECB strategy, SEPA expansion into the Western Balkans, an ECJ opinion that could narrow the definition of payment services, and infrastructure moves in Denmark and Montenegro. For compliance and payment operations teams at EU payment firms, the question is simple: which of these actually require action, and which are just background reading?

I have gone through all seven. Three carry direct operational implications. Two flag strategic shifts that will shape reporting and infrastructure decisions over the next 12 to 18 months. Two are useful context but do not require immediate action. Here is the breakdown.

Related reading: SEPA Instant Payments Regulation: What Changes for EU Payment Service Providers

What the EPC Compilation Covers

The EPC’s Q1 2026 compilation gathers reports from seven sources. The EPC itself does not endorse or author these reports. It curates them as a convenience for the payments industry. The views in each report belong to the original authors.

The seven items are:

  1. Worldpay: 2026 Global Payments Report
  2. ECB: Eurosystem Sets Out Comprehensive Strategy for Future of European Payments (31 March 2026)
  3. SeeNews: Montenegro Moves Closer to Instant Payment Service Launch
  4. A&O Shearman: ECJ C-51/25: Clarifying the Interpretation of Payment Services?
  5. World Bank Group: Cheaper and Faster Payments: SEPA Opens New Horizons for the Western Balkans
  6. Electronic Payments International: Why SEPA Instant Is the Catalyst for Euro Payment Evolution
  7. FinancialIT: Nexi and Danish Banks Expand Agreement to Deliver SEPA Direct Debit Services

Not all of these carry equal weight. A compliance officer at a Luxembourg payment institution and a product manager at a pan-European PSP will read this list differently. What follows is a practitioner-level assessment of each, grouped by operational urgency.

Reports That Require Compliance or Legal Review

ECJ C-51/25: A Potential Narrowing of “Payment Services” Under PSD2

This is the report most likely to trigger work inside legal and compliance teams. The Advocate General’s opinion was delivered on 26 February 2026. The full ECJ ruling typically follows three to six months later, putting a likely ruling date in mid-to-late 2026. The case before the European Court of Justice (Betaal Garant Nederland CV, Case C-51/25) asks whether holding funds in escrow and releasing them on completion of a contract constitutes a payment service under PSD2.

Advocate General Manuel Campos Sánchez-Bordona published an opinion arguing it does not. His reasoning has three parts. First, Betaal held funds in a payment account in its own name, not in accounts belonging to its customers. PSD2’s credit transfer definition under Article 4(3) in conjunction with Annex I, point 3(c) presupposes accounts in the customer’s name. Second, Betaal had no technical involvement in the actual payment processing. The banks supplying the accounts executed the transfers. Third, the customer could cancel the payment if dissatisfied with the construction work, which conflicts with the irrevocability requirement in Article 80(1) PSD2.

The opinion goes further. The Advocate General argues that PSD2’s obligations, including capital requirements and conduct rules, only make sense for entities whose main activity is providing payment services on a commercial basis. This “main activity” test, if adopted by the ECJ, could exclude a range of intermediary models currently treated as payment services in several member states.

Here is what teams commonly get wrong with this case: treating the Advocate General’s opinion as settled law. It is not. The ECJ is not bound by Advocate General opinions, and multiple member states submitted conflicting views. The Dutch government supported the DNB’s classification of the service as a payment service. The Italian government and the European Commission disagreed. The Czech government took a conditional position. Norway classified it as money remittance. That level of divergence signals this question is far from resolved.

If you operate escrow-style models, marketplace payment flows, or hold client funds in omnibus accounts before release, this opinion is directly relevant. Review your licensing basis against the Advocate General’s narrower interpretation and prepare for two scenarios: the ECJ follows the opinion, or it does not. Both outcomes will require documented legal assessments, particularly if your NCA has historically taken an expansive view of what constitutes a payment service.

ECB Comprehensive Payments Strategy: The Policy Direction Is Now Official

On 31 March 2026, the Eurosystem published its comprehensive payments strategy, covering wholesale, business-to-business, retail, and cross-border payments. This is the first time the ECB has unified its payment policy positions into a single strategic document rather than issuing separate retail, wholesale, and digital euro strategies.

The strategy has four stated aims: maintaining the role of central bank money as the anchor of the monetary system; achieving strategic autonomy for European payments infrastructure; fostering integration, competition, and innovation; and supporting the international role of the euro.

For payment firms, three specific elements matter.

First, the strategy explicitly positions the digital euro as a catalyst for pan-European private retail payment solutions, not as a competitor. The Eurosystem confirmed it will build technical capacity for the digital euro ahead of a possible decision to issue in 2029, subject to co-legislators adopting the Digital Euro Regulation in 2026. If you are a PSP in the euro area, the digital euro is moving from consultation to infrastructure build. Product and operations teams that have not started assessing distribution requirements are already behind.

Second, the strategy sets out a position on tokenised settlement assets. For wholesale transactions, the Eurosystem will develop central bank money settlement on DLT through its Pontes and Appia initiatives. Private settlement assets, including tokenised deposits and euro-denominated stablecoins, are acceptable if they are EU-governed and properly regulated. This matters for payment firms exploring tokenised payment rails or stablecoin settlement. The regulatory direction is clearer now than it was six months ago.

Third, the strategy calls for enhanced standardisation and automation in B2B payments, including conditional payments. This signals that the Eurosystem wants to see SEPA schemes evolve beyond basic credit transfers and direct debits. Payment operations teams should expect new interoperability requirements to follow.

The common misread here is treating this document as aspirational only. It is not. The digital euro timeline is concrete. The Pontes pilot is scheduled to launch in Q3 2026, and the Appia roadmap is now in active consultation, with implementation through 2028. The B2B payments ambition will likely feed into PSD3/PSR implementation requirements. This is a policy document that signals where supervisory expectations will land over the next three years.

Reports With Strategic Implications for SEPA-Area PSPs

World Bank: SEPA Expansion Into the Western Balkans Is Working

The World Bank published detailed data on the impact of SEPA accession for Albania, Montenegro, and North Macedonia, which joined SEPA in October 2025. The results are striking. In Montenegro, average B2B cross-border payment costs fell from 73.4 euros per transaction under the prior correspondent banking model to 6.15 euros per SEPA transaction between October 2025 and January 2026. The World Bank describes this as a roughly tenfold reduction in average B2B cross-border payment costs across the three Western Balkan SEPA entrants. For Montenegro specifically, the reduction from the 2024 baseline to the post-SEPA average represents a near twelvefold drop on the headline figures.

For EU payment firms, the operational question is whether your SEPA infrastructure and counterparty databases already cover these new geographies. If you process B2B payments involving Western Balkan counterparties, the cost advantage of routing through SEPA rather than correspondent banking channels is now documented. Sanctions screening and KYC processes need updating to reflect new SEPA-reachable BICs from these countries.

The World Bank report also signals that further Western Balkan economies are expected to join SEPA. Serbia entered SEPA’s geographical scope in May 2025 and is expected to reach full operational readiness in May 2026, joining the SEPA payment schemes alongside the existing four (Albania, Moldova, Montenegro, North Macedonia). Bosnia and Herzegovina has indicated it intends to file its application in 2026, and Kosovo is working on the legislative changes needed to apply. Payment operations teams running static SEPA country lists rather than dynamically updating from the EPC’s official SEPA scheme country list will eventually miss new entrants.

SEPA Instant as the Catalyst for Euro Payment Evolution

The Electronic Payments International article positions SEPA Instant Credit Transfer (SCT Inst) as the foundation for the next phase of euro payment innovation. This aligns with the ECB strategy and with the SEPA Instant Payments Regulation (Regulation (EU) 2024/886), which requires all euro-area PSPs that offer SEPA credit transfers to also offer instant credit transfers.

The compliance deadline pressure here is real. PSPs that have not yet fully onboarded to the SCT Inst scheme are running out of runway. The regulation mandates receiving capability from 9 January 2025 and sending capability from 9 October 2025 for euro-area PSPs. Non-euro-area PSPs offering euro credit transfers have until 9 January 2027 for receiving and 9 July 2027 for sending.

What teams miss: the regulation does not stop at connectivity. It requires charges parity (SCT Inst cannot cost the payer more than a standard SCT), Verification of Payee implementation, and sanctions screening within the instant processing window. Each of these carries its own implementation complexity. If your SCT Inst rollout is treated as a pure connectivity project, you are setting up compliance gaps.

Reports for Background Awareness

Worldpay 2026 Global Payments Report

Worldpay’s annual global report covers payment method trends, e-commerce and point-of-sale payment mixes, and regional adoption patterns. It is useful for product strategy and market sizing but does not carry direct regulatory or compliance implications for EU payment firms. If you are building product roadmaps or pricing models for specific geographies, this report provides market data on digital wallet adoption, card usage trends, and alternative payment method growth.

The report does not address regulatory requirements or reporting obligations. Treat it as market intelligence, not as a compliance input.

Montenegro Instant Payment Service Launch

SeeNews reported on Montenegro’s progress toward launching a domestic instant payment service. Combined with the SEPA accession data from the World Bank report, this signals that Montenegro is building layered payment infrastructure: SEPA for cross-border and a domestic instant payments system for local transactions.

For EU payment firms with no Montenegro exposure, this is context. For those with correspondent relationships or branch activity in the region, it confirms the direction of travel. Domestic instant payments in the Western Balkans will eventually require interoperability testing if your products serve those markets.

Nexi and Danish Banks Expand SEPA Direct Debit Agreement

FinancialIT reported that Nexi has expanded its agreement with Danish banks to deliver SEPA Direct Debit (SDD) services. Denmark, as a non-euro SEPA country, has historically had lower SDD adoption compared to the euro area. This expansion is a market development signal rather than a regulatory event.

For payment firms operating in the Nordic market, it indicates that SDD infrastructure is maturing in Denmark. If your business collects recurring payments from Danish counterparties, the expanding SDD footprint may offer an alternative to existing collection methods. No immediate compliance action is required, but treasury and collections teams may want to revisit their Nordic payment mix.

Operator Checklist: What to Do With This Roundup

Action Report Source Priority Owner
Review escrow, marketplace, and omnibus account models against the Advocate General’s narrower PSD2 interpretation in Case C-51/25. Prepare dual-scenario legal assessment. A&O Shearman / ECJ C-51/25 High Legal / Compliance
Assess digital euro distribution readiness and product implications. Map Pontes/Appia exposure for wholesale settlement. ECB Comprehensive Payments Strategy High Product / Operations
Verify SEPA country lists include Albania, Montenegro, and North Macedonia. Update sanctions screening and counterparty databases. World Bank SEPA Western Balkans Medium Payment Operations / Compliance
Confirm SCT Inst sending and receiving capability is live. Verify charges parity, VoP implementation, and sanctions screening within instant processing windows. Electronic Payments International / SEPA Instant High Payment Operations
Review Nordic payment collection mix for SDD expansion in Denmark. FinancialIT / Nexi Danish SDD Low Treasury / Collections
Monitor ECJ judgment in Case C-51/25. Set calendar alert for ruling. A&O Shearman / ECJ C-51/25 Medium Legal

What to Watch Next

Three items from this roundup will generate follow-on regulatory activity in the coming quarters.

The ECJ ruling in Case C-51/25 will land at some point in 2026. If the Court follows the Advocate General, NCAs across the EU will need to reassess which intermediary models require payment institution licensing. The CSSF in Luxembourg has historically taken a pragmatic but broad view of payment service scope. A narrower ECJ ruling could change that position.

The ECB’s comprehensive payments strategy will feed into the legislative process for PSD3 and the Payment Services Regulation (PSR). Operational requirements for instant payments, open banking access, and tokenised settlement will crystallise as the Commission drafts implementing measures. Payment firms that wait for final text to start planning will face compressed timelines.

SEPA geographic expansion will continue. The EPC’s next update to its official SEPA scheme country list will reflect any further Western Balkan accessions. Payment operations teams should subscribe to the EPC’s country list updates rather than relying on periodic checks.

Frequently Asked Questions

What is the EPC “Around the Web” compilation?

The European Payments Council publishes a quarterly curated list of external reports about the payments industry. The EPC does not author or endorse these reports. It gathers them as a convenience for industry participants. The Q1 2026 edition was published on 21 April 2026 and includes seven items.

Does the ECJ C-51/25 opinion change PSD2 requirements immediately?

No. The Advocate General’s opinion is not binding. The ECJ will issue its own ruling, which may or may not follow the opinion. Until the ECJ rules, existing NCA interpretations remain in force. Payment firms should prepare for both outcomes but should not change their licensing basis solely on the opinion.

What does the ECB comprehensive payments strategy mean for my PSD2 licence?

The strategy itself does not change licensing requirements. It signals the policy direction for PSD3/PSR and the digital euro. Payment firms should use it to anticipate where new obligations will land, particularly around instant payment capability, open banking interoperability, and tokenised settlement assets.

Do I need to update my SEPA reachability for the Western Balkans?

If you process euro-denominated B2B or retail payments involving Albanian, Montenegrin, or North Macedonian counterparties, yes. These countries joined SEPA in October 2025. Your SEPA routing tables, BIC directories, and sanctions screening databases should already reflect this. If they do not, update them now.

What are the key SCT Inst compliance deadlines?

Euro-area PSPs that offer standard SEPA credit transfers must support SCT Inst receiving from 9 January 2025 and sending from 9 October 2025. Non-euro-area PSPs offering euro credit transfers have until 9 January 2027 (receiving) and 9 July 2027 (sending). These deadlines come from Regulation (EU) 2024/886.

Is the Worldpay Global Payments Report relevant for compliance teams?

Not directly. It covers market trends in payment methods, e-commerce, and point-of-sale payment mixes. It is useful for product strategy and market sizing but does not address regulatory obligations or reporting requirements.

How often does the EPC publish these compilations?

The EPC publishes its “Around the Web” compilation roughly quarterly. Each edition covers reports published during the preceding quarter. The compilations are available on the EPC’s news and insights page.

Where can I find the full EPC compilation?

The full Q1 2026 compilation is published on the EPC website at: europeanpaymentscouncil.eu. Links to each individual report are included in the EPC’s listing.

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Key Takeaways

  • The EPC’s Q1 2026 compilation includes seven external reports on payments. Three carry direct compliance or legal implications for EU payment firms.
  • The Advocate General’s opinion in ECJ Case C-51/25 proposes a narrower interpretation of “payment services” under PSD2. If adopted, escrow, marketplace, and omnibus-account models may fall outside PSD2 scope in some member states. This is not settled law yet.
  • The ECB’s comprehensive payments strategy (31 March 2026) is the first unified Eurosystem policy document covering wholesale, B2B, retail, and cross-border payments. It confirms the digital euro timeline targeting readiness to issue by 2029.
  • Albania, Montenegro, and North Macedonia joined SEPA in October 2025. World Bank data shows B2B cross-border payment costs fell roughly twelvefold in Montenegro. PSPs should confirm their SEPA reachability tables and sanctions screening cover these new geographies.
  • SEPA Instant Credit Transfer adoption is accelerating. Regulation (EU) 2024/886 deadlines for sending capability (9 October 2025 for euro-area PSPs) have passed. Non-euro PSPs have until July 2027. Charges parity, VoP, and real-time sanctions screening are the implementation areas where gaps most often appear.
  • The Worldpay Global Payments Report is useful market intelligence but does not require compliance action.
  • Payment operations teams should subscribe to EPC SEPA scheme country list updates and set a monitoring alert for the ECJ ruling in Case C-51/25.

Sources and References

Disclaimer: The information on RegReportingDesk.com is for educational and informational purposes only. It does not constitute legal, regulatory, tax, or compliance advice. Always consult your compliance officer, legal counsel, or the relevant supervisory authority for guidance specific to your institution.

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