Position paper - Instant Payments

Payments are undergoing fundamental changes and instant payments are an important element for an innovative and competitive payments market. While the Commission’s proposal aims to adapt the European system to these changes, we have concerns on the practicality of its requirements.

To best respond to customers’ expectations and demands, a number of elements should be clarified. For instance, the provisions on sanctions screening should be more closely aligned with Payment Service Providers (PSPs)’ broader compliance obligations and practices. Furthermore, the time and cost of necessary investments should not be marginalised. Therefore, both the implementation timelines and the restrictions on fees should be re-assessed. This is particularly true when looking at the proposed provisions on payee verification services. Finally, in light of the upcoming proposal on a Digital Euro, policymakers must ensure alignment between the various legislative developments in the payments area.