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?
Our NCA (Deutsche Bundesbank) just informed us that it will not allow us to take part in the instant payment scheme, because of our iranian background. Our bank in Germany is legally a branch of a foraign bank outsite of the European Union (mother bank is located in Iran).
As our NCA does not let us send or receive instant payments, do we still have to report payment and account data required by the ITS?
We strongly recomment to add an article to the ITS that cancels the reporting requirement if a NCA decides to exclude a PSP from the instant payment scheme.