SEPA Instant Payments Regulation – A Practical Guide for Luxembourg PSPs

ByRegReportingDesk

Updated September 2026

A standard SEPA credit transfer in euro must reach the payee’s payment service provider by the end of the next business day. That D+1 deadline comes from the Payment Services Directive, not from Regulation (EU) No 260/2012, the SEPA Regulation that search queries routinely attach to it. The ten-second obligation this page is built around belongs to a third instrument again, the SEPA Instant Payments Regulation (Regulation (EU) 2024/886). Getting the instrument right matters the moment a payment is late or a customer disputes the timing, so the section below sets each rule beside its legal source.

Execution Time for Ordinary SEPA Credit Transfers

For an ordinary, non-instant SEPA credit transfer in euro, the governing deadline sits in Article 83 of the Payment Services Directive (Directive (EU) 2015/2366, PSD2). The payer’s payment service provider must ensure that the amount is credited to the payee’s payment service provider’s account by the end of the business day following the time of receipt. For payment orders initiated on paper, that time limit may be extended by one further business day. This is the “next business day”, or D+1, standard most people mean when they ask how long a SEPA transfer takes.

Regulation (EU) No 260/2012, the SEPA Regulation, does not set that execution time. It fixes the technical and business requirements that make a euro credit transfer a SEPA transfer: the IBAN as the account identifier, the ISO 20022 message standard, reachability across the Union under a Union-wide scheme, and the migration end dates. Speed of execution is a PSD2 conduct-of-business question; scheme construction is a SEPA Regulation question. A query that cites “260/2012” for the D+1 deadline is pointing at the wrong instrument.

A proposed EU payments package could move these conduct rules again. On 28 June 2023 the European Commission proposed a third Payment Services Directive (PSD3) and a directly applicable Payment Services Regulation (PSR) that would recast the PSD2 framework; the package remains in the EU legislative process, and PSD2 stays the governing text until the successor instruments apply. Our guide to the PSD3 changes for Luxembourg payment and electronic money institutions tracks that transition.

The three instruments that searchers most often conflate line up like this.

RuleLegal instrumentTimingWho it binds
Ordinary credit transfer execution timeDirective (EU) 2015/2366 (PSD2), Article 83Amount credited to the payee’s PSP by the end of the next business day (D+1); paper-initiated orders may take one further business dayPSPs executing payment transactions in euro; Article 82 of PSD2 sets the detailed scope and permitted timing arrangements for payment transactions in other currencies
SEPA scheme and technical requirementsRegulation (EU) No 260/2012 (SEPA Regulation)No single speed rule; IBAN, ISO 20022 messaging, reachability, migration end datesPSPs offering credit transfers or direct debits in euro
Instant credit transfer processingRegulation (EU) 2024/886 (Instant Payments Regulation), amending Regulation (EU) No 260/2012Funds made available to the payee within ten seconds, 24 hours a day, on any calendar dayPSPs that already offer euro credit transfers, phased in by entity type

In Luxembourg, PSD2 is transposed through the amended Law of 10 November 2009 on payment services, as amended by the Law of 20 July 2018 transposing Directive (EU) 2015/2366. The Commission de Surveillance du Secteur Financier (CSSF) authorises and supervises payment institutions and electronic money institutions, and supervises the payment services of credit institutions, so it is the CSSF that oversees compliance with both the execution-time rules and the instant-payments obligations for Luxembourg-established providers.

When the D+1 clock starts depends on the “time of receipt” rule in Article 78 of PSD2. The time of receipt is the moment the payment order reaches the payer’s payment service provider. If that moment is not on a business day for the provider, the order counts as received on the following business day. A provider may also set a cut-off time near the end of a business day, after which an order is treated as received the next business day. An order placed late on a Friday, or over a weekend or public holiday, therefore starts its D+1 count from the next business day, which is why an ordinary transfer can take longer than a single calendar day to arrive.

The Instant Payments Regulation on Top of the Baseline

Luxembourg credit institutions had their first deadline on 9 January 2025. They had to be reachable for instant credit transfers in euro by that date. Their second deadline, sending instant payments, hit on 9 October 2025. For Luxembourg banks that were already live on SCT Inst voluntarily, the regulation mostly formalized existing practice and added new obligations around verification of payee, charges parity, and daily sanctions screening. For banks that had not yet offered instant payments, the 2025 deadlines were a hard forcing function.

Payment institutions and e-money institutions in the euro area are on a different track. Their deadline to both receive and send instant credit transfers is 9 April 2027. That is later, but it is not far away, and the implementation work is substantial. If your payment institution or e-money institution has SEPA credit transfer services in euro and has not started preparing for instant payments, the time to start is now.

Regulation (EU) 2024/886, the Instant Payments Regulation (IPR), published on 19 March 2024, amends the SEPA Regulation (Regulation (EU) No 260/2012). The obligations are real, the deadlines are different by entity type, and the compliance work spans payment infrastructure, fraud controls, pricing, and regulatory reporting.

Related reading: PSD2 Reporting Requirements

What the Regulation Requires

The IPR inserts Articles 5a to 5d into the SEPA Regulation. Article 5a requires PSPs within its scope to offer sending and receiving instant credit transfers and makes reachable payment accounts reachable for instant transfers 24 hours a day and on any calendar day. It also contains requirements on execution, payment-initiation channels, packages of payment orders and PSU-set transaction or daily limits. Articles 5b, 5c and 5d deal respectively with charges, verification of payee and screening for targeted financial restrictive measures. The application dates differ by obligation and, for Article 5a, by PSP type and Member State currency.

Receive Instant Credit Transfers (Article 5a)

A PSP within Article 5a(1), which covers PSPs offering their PSUs a payment service of sending and receiving credit transfers, must ensure that payment accounts reachable for credit transfers are also reachable for instant credit transfers, subject to the applicable phasing and derogations. Funds must be made available to the payee within ten seconds of receipt by the payer’s PSP, at any time of day, on any calendar day of the year.

For euro area credit institutions (including Luxembourg banks), this applied from 9 January 2025. For euro area payment institutions and e-money institutions, the deadline is 9 April 2027. For non-euro area credit institutions, the deadline is 9 January 2027.

Send Instant Credit Transfers (Article 5a)

A PSP within Article 5a(1) must offer its PSUs the sending and receiving of instant credit transfers in accordance with Article 5a and the applicable phasing. Payment accounts reachable for credit transfers must also be reachable for instant credit transfers 24 hours a day and on any calendar day, and payers must be able to place instant-credit-transfer orders through the same payment-initiation channels offered for other credit transfers. Article 5a does not require every payment-initiation channel to be continuously available.

For euro area credit institutions, this obligation applied from 9 October 2025. For euro area payment institutions and e-money institutions, the deadline is 9 April 2027. For non-euro area credit institutions, the deadline is 9 July 2027.

Charges Parity

The charges levied for sending or receiving an instant credit transfer must not exceed the charges for the corresponding non-instant SEPA credit transfer. This is a price cap tied to each institution’s own pricing, not a fixed regulatory amount. If a bank charges EUR 0.20 for a particular type of non-instant credit transfer, the charge for the corresponding type of instant credit transfer for the same PSU cannot exceed EUR 0.20. The comparison is not determined by the payment account alone.

Article 5b has its own application dates. PSPs located in a Member State whose currency is the euro had to comply with the charges-parity rule by 9 January 2025; PSPs located in a Member State whose currency is not the euro must comply by 9 January 2027. The later Article 5a dates for euro-area PIs and EMIs do not postpone Article 5b. Any charge for an instant credit transfer must not exceed the charge for the corresponding type of non-instant credit transfer.

Where the corresponding type of non-instant credit transfer is free for a PSU, the corresponding instant credit transfer must also be free. This is the most commercially sensitive element for institutions whose revenue model included an instant payment fee. The premium cannot be reintroduced after the applicable deadline.

Verification of Payee (Article 5c)

The payer’s PSP must perform the verification immediately after the payer provides the relevant payee information and before the payer is offered the possibility of authorising the credit transfer. Where the payer provides the payee’s IBAN and name, the payer’s PSP must provide the Article 5c verification service based on the matching result provided by the payee’s PSP. This is the confirmation of payee or IBAN-name check requirement. It applies to both instant and non-instant credit transfers, not just to instant payments. The obligation comes from the IPR, but its scope is broader.

Article 5c applies by location, not by the Article 5a PI/EMI derogation: PSPs located in a Member State whose currency is the euro had to comply with verification of payee by 9 October 2025, including payment institutions and electronic money institutions. PSPs located in a Member State whose currency is not the euro must comply by 9 July 2027.

This is the most operationally complex obligation. It requires inter-PSP communication for credit transfers within the scope of Regulation (EU) No 260/2012: the payer’s PSP must be able to obtain the Article 5c verification result from the payee’s PSP. The EU legal obligation should not be generalised to every PSP in the wider SEPA geographical area. The EPC has developed the Verification Of Payee scheme as the interoperability framework. Current and future SCT and/or SCT Inst scheme participants affected by the amended SEPA Regulation’s verification-of-payee provisions are required under the EPC scheme framework to adhere to the VoP scheme and register in the EPC Directory Service; the IPR itself sets the legal Article 5c outcome requirements.

Verification of payee is where implementation effort concentrates. Connecting to the instant payment rails (TIPS or RT1) is largely an infrastructure task. The name-matching logic is where the hard decisions sit: how to handle partial matches, name variations, legal entity names versus trading names, diacritics, abbreviations, and the user experience when a mismatch is flagged.

Sanctions Screening (Article 5d)

Article 5d applies to PSPs that offer instant credit transfers. PSPs subject to Article 5d had to comply with it from 9 January 2025; that compliance date is not phased by PSP type or Member State currency. A PI or EMI that does not yet offer instant credit transfers is not brought within Article 5d merely because it is otherwise a PSP within the SEPA framework.

The obligation: PSPs must verify at least once per calendar day whether any of their payment service users are subject to EU targeted financial restrictive measures. In addition, PSPs must perform an immediate re-check after the entry into force of any new targeted financial restrictive measures or any amendment to such targeted financial restrictive measures.

For targeted financial restrictive measures, Article 5d(2) provides that the payer’s PSP and payee’s PSP must not carry out additional payer/payee screening during execution of an instant credit transfer in addition to the Article 5d(1) PSU screening. That rule is confined to targeted financial restrictive measures and the instant-credit-transfer context; other restrictive measures and Union AML/CFT obligations remain unaffected.

Article 5d(2) expressly preserves actions needed to comply with restrictive measures other than the targeted financial restrictive measures covered by Article 5d, as well as Union AML/CFT law. Article 5d should therefore not be read as displacing those separate obligations. Regulation (EU) 2023/1113 governs information accompanying transfers and related requirements; it should not be described as the general legal source for transaction monitoring.

Article 5d(2)’s prohibition on additional targeted-financial-restrictive-measure screening applies during execution of an instant credit transfer. The IPR does not create an equivalent rule for non-instant credit transfers. Controls for non-instant payments must therefore be assessed under the separate restrictive-measures and AML/CFT requirements that govern them.

The Deadline Map by Entity Type

The phased timeline is more complex than it first appears. There are three variables: obligation type (receive, send, VoP), entity type (credit institution vs PI/EMI), and currency zone (euro vs non-euro area). The table below captures the Luxembourg-relevant euro-area dates and, for comparison, the non-euro-area credit-institution dates; it does not include the separate Article 5a phasing for non-euro-area PIs and EMIs.

ObligationEuro area credit institutionsEuro area PIs and EMIsNon-euro area credit institutions
Receive instant CT9 January 2025 (past)9 April 20279 January 2027
Send instant CT9 October 2025 (past)9 April 20279 July 2027
Verification of payee9 October 2025 (past)9 October 2025 (past)9 July 2027
Charges parity9 January 2025 (past)9 January 2025 (past)9 January 2027
Article 5d targeted-financial-restrictive-measure screening9 January 2025; applies where the PSP offers instant credit transfers9 January 2025 compliance date; applies where the PSP offers instant credit transfers9 January 2025 compliance date; applies where the PSP offers instant credit transfers

For Luxembourg-supervised entities, the most urgent outstanding deadline is 9 April 2027 for payment institutions and e-money institutions. Credit institutions are already past all their 2025 milestones. The non-euro-area dates apply to PSPs located in Member States whose currency is not the euro. A Luxembourg establishment falls under the euro-area dates regardless of where its parent or home institution is based.

Settlement Infrastructure

TIPS and EBA CLEARING’s RT1 are major infrastructures for euro instant payments, but they are not the only possible access or clearing-and-settlement arrangements. PSPs can participate directly or indirectly in TIPS, and TIPS also supports settlement through clearing and settlement mechanisms using ancillary-system technical accounts.

TIPS settles instant payments in central bank money. RT1 participant funds are also central bank money, settled via a TIPS ancillary-system technical account; RT1 should therefore not be described as settling in commercial-bank money through a prefunded guarantee fund. The BCL confirms that TIPS is a TARGET service for final and irrevocable settlement in central bank money.

Sponsoring credit institutions remain one access model, but Regulation (EU) 2024/886 amended the Settlement Finality Directive to make qualifying PIs and EMIs eligible to participate in designated payment systems. The Eurosystem now permits non-bank PSPs meeting the applicable safeguards, operational and technical requirements to access TARGET, including T2 and TIPS, subject to the applicable legal conditions. Settlement architecture should therefore assess both direct and indirect access models rather than treating sponsorship as mandatory.

What This Means for Luxembourg PSPs

Credit Institutions

Luxembourg credit institutions supervised by the CSSF (and the ECB for significant institutions under SSM) are through their 2025 obligations. The regulatory work now is: maintain compliance with the receive and send obligations, operate the verification of payee service, apply charges parity, and run the Article 5d daily sanctions screening. An outage is reportable under DORA only if it constitutes an ICT-related incident that meets the criteria for a major ICT-related incident under DORA Article 19 and Commission Delegated Regulation (EU) 2024/1772; not every instant-payment outage is reportable.

The ongoing operational discipline is the challenge. Running a 24/7/365 payment service with a ten-second SLA and an Article 5d screening process that must respond immediately to new sanctions list updates is a continuous operational commitment, not a one-time compliance project.

Payment Institutions and E-Money Institutions

Luxembourg PIs and EMIs are governed by the amended Law of 10 November 2009 on payment services. Under Article 5a, euro-area PIs and EMIs must offer sending and receiving instant credit transfers by 9 April 2027. Verification of payee under Article 5c applied to PSPs located in euro-area Member States from 9 October 2025, while Article 5d has applied since 9 January 2025 to PSPs that offer instant credit transfers.

Article 5d has a 9 January 2025 compliance date, but its scope is PSPs that offer instant credit transfers. A PI or EMI already offering instant credit transfers must therefore comply with Article 5d; a PI or EMI that does not yet offer instant credit transfers is not made subject to Article 5d solely by the future 9 April 2027 Article 5a deadline.

Institutions Not in Scope

PSPs that do not offer SEPA credit transfers in euro at all (pure payment initiation service providers, pure account information service providers, or institutions operating exclusively in non-euro currencies) are not required to offer instant credit transfers. The obligation is triggered by offering credit transfer services in euro.

Reporting Obligations Under the IPR

Article 15(3) of the amended SEPA Regulation requires PSPs to report annually to their competent authority on two data sets: the level of charges for credit transfers, instant credit transfers, and payment accounts; and the share of payment transactions rejected due to the application of targeted financial restrictive measures, broken down by national and cross-border transactions.

The EBA draft ITS have since been adopted as Commission Implementing Regulation (EU) 2025/1979, which entered into force on 26 October 2025 and now provides the binding uniform reporting templates, instructions and methodology. Article 15(3) of Regulation (EU) No 260/2012 requires PSPs to report every 12 months; its first statutory report date was 9 April 2025. The April 2026 reporting date was the first annual date after the binding ITS entered into force. The ITS contains the templates set out in Annex I, with completion instructions in Annex II. Luxembourg PSPs should use the binding ITS and confirm the CSSF’s current submission mechanics separately.

Common Implementation Challenges

24/7/365 Operations

Ordinary SEPA credit transfers remain subject to PSD2’s time-of-receipt and business-day execution rules; neither PSD2 nor the SEPA Regulation states that they process only during business hours. Instant credit transfers process at any time, including 3 AM on a public holiday. The operating model must be capable of meeting the Regulation’s applicable 24/7 reachability and ten-second execution outcomes. Regulation (EU) No 260/2012 does not prescribe straight-through-processing, queue design or a specific staffing model for exception handling.

DORA’s operational-resilience requirements apply to in-scope financial entities, but whether instant-payment processing is a ‘critical or important function’ must be assessed against DORA’s entity-specific definition. An ICT-related outage must then be classified under the DORA incident criteria, and only a major ICT-related incident is subject to mandatory incident reporting. See our guide to DORA ICT incident reporting for the classification framework.

Verification of Payee Implementation

The name-matching logic has to handle common scenarios: the payer enters “Jean-Pierre Dupont” but the payee’s PSP has “J.P. Dupont.” The payer enters “ABC Trading SARL” but the payee’s PSP has “ABC Trading S.a r.l.” The account belongs to a company but the payer enters the director’s name. The payer’s interface strips diacritics but the payee’s PSP uses them.

Those scenarios can result in a match, an almost match or a mismatch depending on the underlying account data and matching result; the regulation does not predetermine the outcome of those examples. The regulation requires informing the payer of the discrepancy where there is one. How you handle partial matches, what similarity threshold you apply, and how you present the discrepancy in your user interface are implementation decisions with fraud prevention and user experience implications. The EPC’s VoP scheme provides the interoperability framework. Implementation choices within that framework are yours.

Sanctions Screening Transition

Article 5d requires a PSP offering instant credit transfers to verify whether any of its PSUs are subject to targeted financial restrictive measures at least once every calendar day and immediately after new or amended targeted financial restrictive measures enter into force. It does not prescribe a batch-processing architecture or require this control to be implemented as a batch process. The event trigger is the harder part. EU sanctions list updates can occur at any time without advance notice. The control framework must ensure that the required PSU verification is carried out immediately after new or amended targeted financial restrictive measures enter into force. Article 5d prescribes that timing and outcome but does not prescribe a specific technical detection or automation architecture.

This is in addition to, not instead of, existing AML/CFT compliance. Article 5d covers targeted financial sanctions only. Your broader AML obligations under the Transfer of Funds Regulation and Luxembourg AML law are unaffected.

Charges Parity in Practice

The “no higher than corresponding non-instant” rule creates pricing complexity where institutions offer multiple service tiers. Article 5b uses the corresponding type of non-instant credit transfer as the benchmark. Recital 17 states that relevant criteria can include the payment-initiation channel or payment instrument, customer status, and additional features or services. The comparison therefore depends on the characteristics of the corresponding payment offering and should not be reduced to a fixed three-factor test.

If your institution does not charge a PSU for a particular type of non-instant credit transfer, it cannot charge that PSU for the corresponding type of instant credit transfer. The instant payment premium disappears. For institutions that generated revenue from this premium, the pricing adjustment is a commercial consequence of the regulation, not an implementation choice.

Frequently Asked Questions

Are payment institutions required to offer instant payments?

Yes, where Article 5a applies. Euro-area payment institutions and electronic money institutions must offer sending and receiving instant credit transfers by 9 April 2027. Other IPR dates are different: Article 5b charges parity applied to euro-area PSPs from 9 January 2025, and Article 5c verification of payee from 9 October 2025. Article 5d has a 9 January 2025 compliance date but applies to PSPs that offer instant credit transfers; it is not an unconditional obligation on every PI or EMI that does not yet offer instant credit transfers.

What happens if we cannot process a payment within ten seconds?

Article 5a requires the payee’s PSP to make the funds available and confirm completion within ten seconds of the payer’s PSP receiving the payment order. If the payer’s PSP does not receive confirmation within that period, Article 5a(5) requires it immediately to restore the payer’s payment account to the position it would have been in had the transaction not taken place. A VoP discrepancy is not itself a mandatory rejection: Article 5c(5) requires the verification service not to prevent the payer from authorising the credit transfer.

Does the regulation apply to payments above EUR 100,000?

The current 2025 SCT Inst Rulebook v1.1 no longer applies a default maximum amount at scheme level. Article 5a(6) instead requires a PSP, at the PSU’s request, to allow the PSU to set a maximum amount on a per-day or per-transaction basis and to modify that limit before placing an instant-credit-transfer order. A separate limited derogation exists in Article 5a(2) for certain PSPs in non-euro Member States, subject to competent-authority permission and a regulatory floor of EUR 25,000. The historic SCT Inst scheme cap should not be used as the current rule.

How does verification of payee work for cross-border payments?

The VoP obligation applies to euro credit transfers within the scope of Article 5c and Regulation (EU) No 260/2012, including cross-border transfers within that regulatory scope. A Luxembourg bank initiating a payment to a German beneficiary must therefore be able to obtain the Article 5c verification result from the German payee’s PSP. The obligation should not be generalised to every PSP in the wider SEPA geographical area; PSPs outside the EU regulatory scope are subject to the applicable local legal and EPC scheme conditions.

Do we need to report rejections caused by sanctions screening?

Yes. Article 15(3)(b) of the amended SEPA Regulation requires reporting every 12 months to the competent authority on the share of rejections due to targeted financial restrictive measures, separately for national and cross-border payment transactions. The binding templates, instructions and methodology are now set by Commission Implementing Regulation (EU) 2025/1979.

What if our settlement agent does not support instant payments by our deadline?

A PSP whose chosen settlement model depends on a sponsoring institution has a material dependency if that sponsor cannot support instant payments by the applicable deadline. Sponsorship is not the only possible model: qualifying non-bank PSPs may also access designated payment systems, including TARGET/TIPS, subject to the applicable participation conditions. The regulatory deadline does not shift because a chosen settlement provider is not ready.

Does the IPR affect our DORA obligations?

DORA applies to ICT risk supporting instant payments, but it does not automatically classify instant-payment processing as a critical or important function for every entity. An ICT-related outage must be assessed against the DORA major-incident criteria before it becomes reportable. The DORA Register of Information covers contractual arrangements for the use of ICT services supplied by ICT third-party service providers; a settlement agent or other provider is included only to the extent that the relevant arrangement is for an ICT service within DORA’s scope.

  • PSD2 Reporting Requirements: The authorization framework for payment institutions and e-money institutions. IPR obligations apply to PSD2-authorized PSPs.
  • AML Reporting in Luxembourg: Article 5d sanctions screening sits alongside, not instead of, the full AML framework. Both apply to Luxembourg PSPs.
  • AMLR – What Changes for Luxembourg Firms: The incoming EU AML Regulation will further shape sanctions and customer screening obligations that overlap with Article 5d.
  • DORA ICT Incident Reporting: An instant-payment outage caused by an ICT-related event may constitute an ICT-related incident; mandatory reporting depends on whether the major-incident criteria are met.
  • DORA Register of Information: Contractual arrangements for the use of ICT services provided by ICT third-party service providers must be included in the DORA register of information; whether a settlement agent or other provider is included depends on whether the relevant arrangement is for an ICT service within DORA’s scope.
  • MiCAR Reporting Obligations: MiCAR and the instant-payments framework are separate regulatory regimes; an e-money-token transfer is not, merely because it is an EMT transfer, a credit transfer under Regulation (EU) No 260/2012.
  • CESOP Reporting Explained: CESOP reporting can cover qualifying cross-border credit-transfer payments, including instant credit transfers, where the statutory conditions are met; the quantitative trigger is more than 25 cross-border payments to the same payee in a calendar quarter, not a minimum payment amount.

Key Takeaways

  • An ordinary SEPA credit transfer in euro must reach the payee’s PSP by the end of the next business day (D+1), a rule set by Article 83 of PSD2, not by Regulation (EU) No 260/2012. Paper-initiated orders may take one further business day.
  • Article 5a(1) applies to PSPs that offer their PSUs a payment service of sending and receiving credit transfers; those PSPs must offer sending and receiving instant credit transfers in euro, subject to the Article 5a phasing and derogations. Credit institutions in the euro area (including Luxembourg) had their deadlines in January and October 2025. Payment institutions and e-money institutions in the euro area have until 9 April 2027.
  • Non-euro area credit institutions must receive instant payments by 9 January 2027 and send them by 9 July 2027.
  • Article 5d has applied since 9 January 2025 to PSPs that offer instant credit transfers. The compliance date itself is not phased by entity type, but Article 5d should not be described as applying to a PI or EMI that does not yet offer instant credit transfers.
  • Verification of payee applies to credit transfers within Article 5c, including instant and non-instant credit transfers. PSPs located in euro-area Member States, including PIs and EMIs, had to comply from 9 October 2025; PSPs located in non-euro Member States must comply from 9 July 2027.
  • Charges parity under Article 5b applied to all euro-area PSPs from 9 January 2025, and to non-euro-area PSPs from 9 January 2027. The later Article 5a dates for euro-area PIs and EMIs do not postpone Article 5b. No premium is permitted after the applicable deadline.
  • PIs and EMIs can use indirect settlement arrangements, including sponsorship, but qualifying non-bank PSPs may also access designated payment systems and TARGET/TIPS directly subject to the applicable participation requirements. Institutions should confirm the settlement model that will support their Article 5a obligations before April 2027.
  • Reporting every 12 months to the competent authority on charges and sanctions-related rejection rates now uses the binding templates in Commission Implementing Regulation (EU) 2025/1979. Article 15 sets 9 April as the annual PSP reporting date and 9 October as the annual competent-authority transmission date to the EBA and Commission.

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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