Instant payments in euro

European Digital Finance Association and its members representing thousands of fintechs throughout Europe welcome the proposed regulation to cater for speed in payment transfers in the consumer perspective. We acknowledge the fact that the financial system is not able to provide instant payments to European citizens at large.

YUTA sector, within MonTiN Safe administration, has recognized instant payment as a very important instrument for integration of the multimodal traveling, central international currency exchange, removing fragility in functioning of the linked business processes (which is very important for tourism sector), and, therefore - as a necessary building brigs of global digital economy.

The EMA welcomes the Commissions proposals to improve the supply of instant payments across Europe, and tackle the key issues that have hampered the uptake of instant payment in euro. We share the Commissions view that SEPA instant payments have the capacity to form the foundations to support the EU retail payments strategy.

As the private sector operator of the pan-European SEPA payment systems STEP2-T and RT1, EBA CLEARING welcomes the opportunity to provide feedback on the Proposed Regulation. As a user-governed organisation, EBA CLEARING has reviewed and discussed with its users the potential impact of the Proposed Regulation on private-sector payment systems. Please see attached EBA CLEARING's detailed observations on the Proposal.

We welcome the opportunity to how on the EU Commission’s proposal for current payments. Please finish attached the French Payments Committee’s position paper (in French). We thank you for the attention you will see to these marks, and hand at your disposal for further clarification.

Filed in French · English published by the European Commission

Dear Sir/Madam, The Banking & Payments Federation (BPFI) welcome the opportunity to provide feedback on the SEPA Instant legislative proposal. We have been engaging with our colleagues in the European Banking Federation (EBF) and we would like to confirm we are supportive of the EBF position submitted, which is a good reflection on the current views of the Irish Community from our membership base. Kind regards.

The French banking community welcomes the European Commission's decision to promote instant payments. However, the European Commission's text proposal on instant payments raises questions at different levels and therefore leads the French banking community to propose adjustments to the four proposed pillars. Please find attached a document that presents the major points of our analysis of the text.

Please find attached the Position Paper of the Association of Foreign Banks in Germany of 5 January 2023 on the Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL amending Regulations (EU) No 260/2012 and (EU) 2021/1230 as regards instant credit transfers in Euro.

Dear madam or sir, The Dutch Payments Association welcomes the opportunity to provide feedback to the proposal of the European Commission regarding instant payments. Please find attached our response. In this file we explain our main views to the proposaland suggest specific amendments regarding the proposed regulation. We hope to make a meaningful contribution. Kind regards, [name removed]

We are a tiny bank (and a PSP too) in an EU member state but outside the euro area, and we have a foreign branch in a country that is also an EU member state and in euro area. The headquarter of the bank is in the country outside the euro area. Please find attached our comments and suggestions.

The draft European regulation significantly affects payment products by instant transfer via telephone number such as Paylib for four reasons: 1/le client does not know Lebanon of his beneficiary 2/il very rarely enters the beneficiary’s civil status correctly and strictly, either because he uses a diminutive from his address book (‘Maman’, ‘My heart’, ‘Pierre’, ‘Biquette’) or because he simplifies it as a…

Filed in French · English published by the European Commission

Febelfin welcome the proposal for legislating instant credit transfers (SCT Inst). SCT Inst are an important building block of the future EU payments market. Statistics show SCT Inst are already widely adopted and offered in Belgium. Today about half of Belgian institutions offering credit transfers, offer SCT Inst, these cover 96,5 % of all payment accounts in Belgium.

The Spanish Banking Association (AEB in its acronym) welcomes the opportunity to provide comments in the context of the public participation process on the Regulation amending the SEPA Regulation and the Regulation on cross-border payments as regards instant credit transfers.

Bitkom welcomes the Commissions proposal to accelerate the rollout of instant payments as an opportunity to drive further innovation in payment services. We recognise the opportunity to provide feedback on the proposed regulation. Our preliminary position paper lays out our ideas on how the draft regulation can be further developed with regard to the scope, pricing, and IBAN name checking.

Filed in German · English published by the European Commission

ETPPA welcomes the European Commissions legislative proposal for a regulation on instant payments. A regulation to secure the wide-spread availability of instant payments has long been a missing brick in the PSD2 ecosystem.

Intesa Sanpaolo, one of the top banking groups in the European Union, welcomes the opportunity to provide preliminary feed-back to the co-legislators about the European Commissions proposal for an Instant Payment Regulation. As highlighted in other European Commissions public consultations, Intesa Sanpaolo fully supports the development of Instant Payments (IPs) across EU countries.

Por la presente se adjuntan los comentarios de ASNEF (nº de Registro de Transparencia 11218815591-29) relativos a la propuesta de Reglamento sobre transferencias inmediatas y, en concreto, en relación con los Artículos 5 quáter, apartado 1 y 5 quinquies, apartado 3.

EuroCommerce and its members welcome the proposed regulation and are keen to see instant payments in the retail environment develop into an additional fast and secure payment method. We do have some concerns and suggestions as follows: 1. We call on the Commission and other institutions to promote coherence/convergence between the various European market participants that may offer SCT Inst based payment solutions.

DECO, the Portuguese Consumer Protection Association, welcomes the proposal for a Regulation on Instant payments (IPs). To achieve a widespread take up of IPs, especially from consumers, it is crucial to have a regulatory framework making them available, accessible, and secure.

Dear Commission, in accepting the invitation in the consultation paper on the Proposal for a regulation of the European Parliament and of the Council on amending Regulations (EU) No 260/2012 and (EU) 2021/1230 as regards instant credit transfers in euro, ANASF - National Association of Financial Advisors intends to express the following remarks.

ACCIE welcomes the Commissions proposal on Instant Payments (IPs), which will help increase consumer choice regarding preferred payment methods. ACCIE appreciates that the proposal addresses consistency with existing legislation such as PSD2 and the Regulation on Cross-Border Payments.

Dear Sir or Madam, M|E|W Consul as Risk Management Company naturally supports European Commissions initiative to promote instant payment. Experience shows, only an integrated structure will achieve wide adoption. Meaning, payments to and from retail is as important as payments made between businesses. B2B, meaning incoming and outgoing payments at the same time, requires update to liquidity management system.

DIGITALEUROPE believes the baseline policy option detailed in the inception impact assessment is the most suitable to advance instant payments today in Europe. At this stage, monitoring the market evolution and assessing the effects of voluntary efforts is the most sensible decision to foster the growth of instant payments, while the industry works to address their challenges. Please see attached our response.

Bizum is the value-added services A2A payments built over the SCT Inst rails by Spanish banks. Bizum has already developed a successful business model involving merchants (online and physical) leveraging instant payments (2021: +20 M consumers & +20.000 merchants).

ESBG and its Members fully support efforts to increase the uptake of SCTInst and share the view that it could facilitate stronger and more integrated homegrown pan-EU payment solutions. The EC should foster an environment that enables the uptake of instant payments, e.g.

The French Payments Committee gathers representatives from the offer and demand side of the payments industry, together with relevant public authorities. The CNPS had responded to the Commission’s 2020 consultation on its retail payments strategy. A. The CNPS concurs on the necessity to guarantee a wide coverage of IPs at the EU level, to benefit from network effects.

SIA, European leader in the design, creation and management of technology infrastructures and services for Financial Institutions, Central Banks, Corporates and the Public Sector is grateful to make available its competences and experience to the European Commission and provide a feedback to the inception impact assessment on policy options to support the development of instant payments.

The Smart Payment Association (SPA) s an organization of major european security technology vendors for the financial industry. SPA is particularly active in the production of both SEPA and Global standards for retail payment systems with a focus on innovation and consumer protection. Our position is summarized in four points: 1. Promote standards for the interoperable selection of Instant Payments at the POI 2.

Feedback on the European Commission (EC) ’s Roadmap (Inception Impact Assessment) on Instant Payments in the EU This feedback emanates from the Group Caisse des Dépôts which already answered to the European Commission ‘s consultation on a retail payments strategy for the EU. A.

The National Association of German Cooperative Banks (BVR e. V.) is the umbrella association of the cooperative banking sector in Germany. The “Volksbanken Raiffeisenbanken Cooperative Financial Network” (Genossenschaftliche FinanzGruppe Volksbanken Raiffeisenbanken) is the Cooperative Banking Group in Germany with currently (end of 2020) 814 individual small and medium regional oriented cooperative banks.

AFTE, Association of Enterprise Treasurers, welcomes the European Commission’s initiative to promote instant payments at European level and seek the views of the various market players. AFTE is already strongly involved with its members on the subject and supports the deployment of instant payments in a broad and accelerated manner.

Filed in French · English published by the European Commission

Wise welcomes the opportunity to provide feedback on the European Commission’s initiatives on instant payments. We were heartened to see instant payments becoming a true pillar of the Commission’s Retail Payments Strategy and applaud the ambition to make instant payments the norm across the EU.

The Impact Assessment establishes several objectives: "making cross-border payments easier, faster and cheaper", "ensuring citizens and companies have high quality, secure and cost-efficient payment solutions to make all their payments, both domestically and cross-border”, "reduce fragmentation in the internal market, sovereignty in payment solutions".

ING fully subscribes the importance of instant payment for the EU internal market. We believe it is crucial to process payments – both national and cross-border within the SEPA area - for citizens and companies in Europe in a real-time, reliable, cost-efficient and secure way as backbone for enabling pan-European market initiatives based on instant payments.

Generally speaking, amending legislation should only be a last resort when alternative, socially less costly forms of public intervention are exhausted. We therefore prefer a non-legislative solution to the problem of slow extension of instant payments with one exception.

Filed in Czech · English published by the European Commission

The EPC supports the European Commission’s overall objective, i.e., “to foster pan-European market initiatives based on instant payments, which would ensure that anyone holding a payment account in the EU could be able to receive and send an instant credit transfer from and to any other payment account in the EU.” The EPC believes in the market-led deployment of instant payments which has proven a success in several…

Intesa Sanpaolo agrees that a lack of well-functioning instant credit transfer solution that could fully rely on European payments infrastructure obliges most of the European PSPs to be dependent on global players, being them cards or more and more Big Techs for EU cross-border card payments. We share the EC concerns on the still low level of adherence to the SCT Inst scheme by EU PSPs.

ETPPA, the European trade association of bank-independent Third Party Providers (TPPs) under PSD2, very much welcomes the EC’s initiative in promoting instant payments and its Inception Impact Assessment, which we hereby would like to comment on: We fully agree that instant payments shall become the new normal and agree to the EC’s Retail Payments Strategy supporting this objective.

To achieve truly functional instant payments across Europe it is important to have interoperability at the heart of any new system, to ensure compatibility and to prevent barriers that could hamper the effectiveness of such a scheme. When designing an Instant payments scheme there should be a dual focus on domestic/national level payments and cross-border payments, to ensure a seamless integration.

EPIF welcomes the opportunity to provide our views to the Commission Inception Impact Assessment on Instant Payments. We would like to take this opportunity to share with you some general comments that our members have on this issue.

According to Bitkom, instant payments offer added value across all payment use cases. As supporters of a technology-neutral approach, however, we also want to stress the merit of digital payment solutions in general. Hence, we consider instant payments as complementary to existing products and as enabler for new payment solutions and products (e.g. Instant Lending).

We would like to express our concern that the first part of the consultation on Instant Payments (targeted consultation) was published before the end of the deadline for feedback on the Impact Assessment. The SEPA Instant credit transfer ("Instant Payments/ SCT Inst") is an important enrichment of the payments service offering in SEPA, which is well accepted by customers from an actual demand.

American Express supports the initiatives by the Commission encourage instant payments across the EU. The design of such initiatives should consider all possible barriers to instant payments to ensure further adoption by consumers and businesses alike. A more developed instant payments infrastructure will open opportunities for payment initiation and acquiring in particular.

> > Challenges: Gisad welcomes the European Commission’s initiative to harmonise instant payments. Legislation should already take account of the new possibilities offered by the introduction of an EU-D-S. Cash is still used in many cases today because it is simple and safe and because it can be bought anonymously. In principle, cash can be replaced by digital means of payment if these conditions are met.

Filed in German · English published by the European Commission

Dear Sir or Madam, We appreciate the opportunity to provide input to the inception impact assessment document Ares(2021)1648321 on Instant Payments. Please find enclosed our position paper of 7 April 2021 concerning the following topics: (i) Directive or Regulation (ii) Implications of mandatory adherence to SEPA Instant Credit Transfers (iii) Compliance risks for PSPs (iv) Voluntary adherence as an alternative Kind…

Please find attached general feedback on the Roadmap on behalf of DKB, with 4.6 million clients and 4.500 employees one of Germany's largest banks, to be complemented by more specific responses to the recently launched targeted and public consultations on instant payments.

P27 shares the European Commission’s vision about the opportunities and benefits instant payments can bring to the European payments market. While we agree there are a number of obstacles that businesses have to overcome in order to create pan-European cross-border payment products, we would argue that the basic conditions do exists – as showcased by P27’s example in the Nordics. The attached letter outlines this.

Since 2018, Ingka Group, the strategic partner in the IKEA franchise system, has embarked on a journey to transform into a retailer fit for the 21st century. We are becoming an omnichannel retailer, using payment solutions to meet customers wherever and whenever they choose, with the products and services they want, always at prices they can afford.

Mastercard welcomes the opportunity to feedback on the Commission’s initiative on instant payments. Electronic payments are the foundation of the digital economy in Europe. We see the importance of giving consumers and businesses access to the full range of electronic payment types including cards, instant payments and hybrid services as well as non-digital payments - such as cash.

DATEV eG welcomes the opportunity to provide feedback on the European Commission’s Inception Impact Assessment on an initiative on instant payments in the EU. DATEV approves the EU Commission’s intention to foster SEPA Instant Payments in order to strengthen the Single Market of financial services and thereby to enhance Europe’s digital sovereignty.

The ECSG (European Cards Stakeholders Group), a multi-stakeholder association promoting card harmonisation in the Single Euro Payments Area (SEPA) made up of representatives from all five sectors of the card payment chain, took note with interest of the European Commission’s inception impact assessment on policy options to broaden the current offer of payment solutions at the point of interaction for European…

Please see attached paper in which Payments Europe recommends that with this Inception Impact Assessment, the EC pursues the proposed baseline option (1), which includes monitoring the market evolution and assessing the effects of voluntary efforts to put forward initiatives delivering on the above objectives, as the most effective means of enabling the market to continue innovating to meet consumer needs.

The Association of Credit Card Issuers Europe (ACCIE) is pleased to submit commentary on the roadmap on instant payments, and would like to bring to the Commission’s attention the following points: - Instant payments should be considered complementary to other payment methods, as different payment methods differ in their features, being more favourable to certain payment needs.

We would prefer tax cuts. (1) Reducing non-wage labour costs on a permanent basis 2.) End cold progression (3) Reduce company taxes significantly during the period of coronavirus restrictions (4) Promote a significant increase in working lives, thus providing for retirement at a higher age, thus relieving the burden on the pension fund.

Filed in German · English published by the European Commission

We very much support the Commission’s plan to organize public consultation, to inform citizens and stakeholders as well as to ensure an opportunity to provide feedback. As regards to the policy options, we would like to stress that the market effort has not yet been sufficient, therefore we would support more active role to be taken by the policy makers.

Polish Organization of Non-Banking Payment Institutions ("PONIP") supports pan-European market initiatives addressing instant payments. The design of any such initiative must consider as broad perspective as possible to bring the expected results.

Currently, instant transfer costs may vary from a few cents to more than EUR 3 per transaction, as not all banks are parties to the Europe Agreement. We believe that the cost of progress and innovation should be a competitive factor between businesses, and we therefore hope that the cost of an instant transfer, which consists of an electronic transaction, should be eliminated.

Filed in Italian · English published by the European Commission