Response to consultation on draft implementing technical standards for uniform reporting under the Single Euro Payments Area Regulation
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?
The reporting as proposed by the EBA presents a major burden for reporting entities. At the same time added value of such detailed reporting is not clear in all cases. Please find proposal for adjustment of the reporting concept.
Number and value of credit transfers and instant credit transfers
- Issue: Instant payments should not be treated as a subcategory of credit transfers since they represent along with regular SCT payments that have migrated from cash (IP P2P) and cards (payments at POI).
Depending on payment habits and trends in Member states (at a later migration stage) the subcategory of instant payments may even exceed the core category of regular credit transfers.
Proposal: Sensible differentiation of reporting categories is needed to ensure 1:1 comparability of data.
- Issue: Proposal for data of volumes and values of instant and regular credit transfers reporting is a duplication of reporting for the ECB payments statistics purposes.
Added value of duplicative reporting is not clear. However, it is noted that in line with the 5th paragraph in Annex II, describing scope of reporting that (only) a reference to the already reported data – if allowed by NCA – could be provided.
Proposal: To ensure level playing field please define clearly, which data is to be reported by payment service providers as opposed to making this an autonomous decision of NCA. At the same time do consider that it is urgent to de-burden reporting entities by recycling as much of the already reported data as possible, while also considering that too detailed reporting may exceed the purpose of reporting which is to support the authorities in their understanding of the extent in which the IPR affected trends in usage of instant payments.
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?
Charges for credit transfers and instant credit transfers
- Issue: The proposed reporting concept of charges is complicated and may not ensure comparability as was even stated in the rationale. Furthermore, the proposed reporting is a deviation from the existing reporting for the purpose of (fee) comparison websites (reporting fees for representative services based on price lists, as opposed to costs that were charged). Thus, the proposed reporting is considered a major burden, while at the same time added value is not clear. Payment service providers being obliged to offer instant payments in line with IPR have no motive for the provision of instant payment services as a premium service. The main motivation will be quite opposite, i.e. achievement of economies of scale. An effect of the obligation for the provision of instant payments will be increased competition amongst payment service providers. A natural consequence will be the lowering of fees for instant payments. Furthermore, the proposed reporting exceeds the purpose of the IPR which is limited to harmonizing fees for instant payments with the fees for regular credit transfers.
Proposal: The reporting should be simplified and comparable to the IPR requirements on charges for payment service providers. The data already reported by payment service providers for the purpose of fee comparison websites should be recycled (e.g. Fees for providing payments services). The reporting concept on charges should take into consideration that the main indicator of effective pricing policy will be the rising usage of instant payments.