Response to consultation on draft implementing technical standards for uniform reporting under the Single Euro Payments Area Regulation
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?
Rabobank would prefer a single data flow with regard to definitions in order to avoid different interpretations, to ensure data minimisation and to avoid duplication and excessive reporting burden.
At this moment Rabobank reports data via templates to our national bank De Nederlandsche Bank (DNB) for payment statistic purposes. It would be preferable to add extra data requirements in the existing templates.
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?
In our view, the reporting requirements proposed in templates S 01.00 and S 02.00 are an excessive reporting burden.
As we do not charge our clients extra for instant payments, we do not have separate data on charges for SEPA credit transfers and for Instant Payment transfers.
When it comes to separating the costs for SEPA credit transfers and Instant Payment transfer, it would not only require disproportionate effort, but it would also be a contrived exercise. Please consider that for Rabobank the standard for payment transactions on an individual basis has been Instant Payment since 2019.
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?
First we are the opinion that collecting data on accounts and related total expenses may not provide a comprehensive measure for assessing the impacts of instant payment pricing. Rabobank offers a wide range of account models with different scopes of services and related to this, different price models. Moreover, if the objective of collecting the data is linked to consumer protection, as clearly stated on the slides of the Public Hearing of Oct. 9 2024, why should PSPs report corporate clients’ data?
Secondly, the reporting of SOF like data will be an excessive reporting burden. So far we have been used to report on SOF data only to private/consumer clients.
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?
Regarding the reporting requirements we suggest to focus on transaction charges, please leave out the account maintenance and the overall annual cost of the payment account. The overall annual cost of the payment account will cover much more than relevant within the scope.
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?
NA
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 following terms definitions and requirement require to be defined further:
- the definition of "consumer".
- The definition of “costs”.
- It is not clear to us whether Swift Payments in EUR within EU should be included or whether the scope is limited to SEPA Credit Transfers and SEPA Instant Payments.
7. Do you perceive the reporting requirements to be proportionate? Is there information contained in the templates that is overly burdensome to report?
As indicated in question 3: overly burdensome will be S 03.00 0030. And the high level of granularity of all data requests is also burdensome.
8. Do you have any other comments on the reporting requirements proposed in this CP?
We would like to highlight that the proposed timeline for the reporting requirements is highly unrealistic. According to the draft ITS, the final technical standards (e.g., XML specifications) will be available by the end of 2024. Then our supervisory authorities (in the Netherlands AFM and DNB) should develop their reporting templates. The first report is expected by 9 April 2025 about a period dating back to Oct. 26 2022.
This allows banks less than three months to analyse the technical specifications and implement a reporting system for historical transactions dating back more than two years.
Rabobank was disappointed to hear during the Public Hearing of Oct. 9, 2024, the only reason for Oct. 26 2022 as a report starting date was the negative assumption from the EBA that PSPs would immediately increase their level of charges because of the obligation in the on Oct. 26, 2022 published first draft version of the Instant Payments regulation. This obligation requires not to charge payers and payees higher for instant credit transfers than for other credit transfers (article 5b).
In our view it should be reconsidered whether an evaluation of data from 2022 onwards is useful, necessary and proportionate as this will be an excessive reporting burden for PSPs.
Finally: do we know whether we are complying with all other legislation now that we have to deliver such many data on our clients?