Response to consultation on draft implementing technical standards for uniform reporting under the Single Euro Payments Area Regulation

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8. Do you have any other comments on the reporting requirements proposed in this CP?

In accordance with Article 15 of REGULATION (EU) 2024/886 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 13 March 2024, amending Regulations (EU) No 260/2012 and (EU) 2021/1230 and Directives 98/26/EC and (EU) 2015/2366 as regards instant credit transfers in euros, and the document "Consultation paper on ITS under SEPA Regulation - Annex II - instructions for PSPs," banks will carry out annual reporting: the number and value of credit transfers, instant credit transfers, fees, the number of payment accounts, and the proportion of transactions rejected due to EU restrictive measures. The first report is scheduled by 9 April 2025 and will include data from 26 October 2022, the entire year 2023, and 2024. After that, annual reports will follow by 9 April with data for the previous year.

  1. We are interested in the method of submitting this annual report. Is it expected to submit this report to the regulator in an Excel spreadsheet, as indicated in the document "Consultation paper on ITS under SEPA Regulation - Annex II - instructions for PSPs," or is another method anticipated?
  2. Regarding the reporting of the number and value of credit transfers, we have a dilemma as to whether in chapters 1. NUMBER AND VALUE OF CREDIT TRANSFERS and 2. CHARGES FOR CREDIT TRANSFERS, we report the values that relate only to outflows from the accounts of clients we manage at the bank (and the corresponding fees), or whether the reporting also includes all inflows to the accounts of clients we manage at the bank (and the corresponding fees)?
  3. Concerning the reporting of the number and value of credit transfers, we are wondering whether in 1. NUMBER AND VALUE OF CREDIT TRANSFERS, the total number and value of transactions (reporting codes 0010 to 0040) must match the sum of credit transactions through online banking, mobile banking, and paper payment orders (codes 0290 to 0400)?
  4. Where should credit transactions executed by Standing Order and payments based on court orders be classified? Is it correct to categorize them under paper orders?

Name of the organization

BANK ASSOCIATION OF SLOVENIA