Response to consultation on draft implementing technical standards for uniform reporting under the Single Euro Payments Area Regulation
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1. Do you perceive that the reporting requirements adequately cater for the situation where the PSP has already reported the same data to the authorities?
In general, the reporting requirements are adequate, but we don’t think it is necessary to provide information since 2022. It would be enough to report data from this year.
2. Do you consider the reporting requirements proposed in templates S 01.00 and S 02.00 to be suitable for carrying out a robust analysis and to strike an appropriate balance with the competing need to avoid excessive reporting burden for the industry?
We consider that the reporting requirements are a bit exhaustive as we don’t have information about credit transfers classified by payment initiation method from past years.
3. Do you consider the reporting requirements proposed in templates S 03.00 to be suitable for carrying out a robust analysis and to strike an appropriate balance with the competing need to avoid excessive reporting burden for the industry?
Yes, the reporting requirements are suitable
4. Do you consider that the reporting requirements on the charges for payment accounts and credit transfers will allow for a robust analysis of charges for such individual financial services where they are provided as part of a package of services? How could robustness be improved to strike the right balance between collecting relevant data and not overburdening the PSPs?
Yes, we do
5. Do you agree that, in light of the aims of the underlying regulation, there is a need for template S 04.00 to collect data on the number of rejected transactions on the side of the payer’s and payee’s PSP prior to the application of the IPR amendments to SEPA Regulation, and rejected transactions on the side of the payer’s PSP, and frozen funds on the side of the payee’s PSP, after the application of the IPR amendments to SEPA Regulation?
It could be suitable, but we don’t have such historical data. We can only provide data from 2024.
6. Are the instructions and templates in Annex I and II clear to you or do any of the terms therein require to be defined further?
The instructions and templates are clear
7. Do you perceive the reporting requirements to be proportionate? Is there information contained in the templates that is overly burdensome to report?
As stated before, historical data is difficult to report in some cases as we did not have a need to register it