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?
Banks have expressed concerns about redundancies between existing reporting requirements and new requests. Some data is already provided to authorities such as the ECB or in other reporting formats, but there are differences that would require further adaptations to information systems, resulting in additional costs and time.
Some banks consider that the current coverage is partial and will require additional developments (hence additional cost and time) to meet the new requirements. Others pointed out that some data is not yet collected, which would complicate its extraction and presentation.
Clarifications were requested on the exact scope of the requirements (data that appears to be identical has different definitions), in particular on the accounts to be included, the types of transactions, and on special cases such as territories outside the European Union but regulated by a national authority.
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 industry believes that it would be more appropriate to provide a price list for instant and standard transfers. In the majority of cases, the transfer is not priced individually but rather as part of a package. This makes it much more complex and arbitrary to provide this information (which would de facto be erroneous and difficult to compare from one institution to another).
The requirements are considered to be very detailed, which would entail a significant burden, particularly in terms of identifying customer types and payment initiation channels. Some acquiring channels, such as bulk (file) transactions, are not mentioned in the current models, raising questions about their inclusion.
For some banks, these requirements exceed their internal needs, and the short implementation time is a challenge. Some information is already available in clearing systems, but with different definitions than the new requirements.
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?
The information requested on account management fees does not relate solely to the costs of transfers (it includes several services) and the industry therefore considers that this information is not relevant to the monitoring of the IP Regulation.
The banks are concerned about the impact on the resources and systems needed to extract this data, and the associated cost. The industry believes that it would be more appropriate to provide the fee schedule for instant and standard transfers.
The reporting of charges including several services (such as credit cards, payment terminals, etc.) might not provide an accurate view to regulators, and banks might be forced to provide estimates, which would reduce the quality of the data.
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?
The diversity of tariff structures and customer types makes it difficult to analyse costs in a global way. Pricing practices vary between retail customers, SMEs and large corporates, making unified reporting complicated.
Some banks believe that a global analysis is the only realistic option, as banking packages often include multiple elements that cannot be easily separated for reporting purposes.
The industry believes that it would be more appropriate to provide a price list for instant and standard transfers.
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 is the industry's understanding that rejections will be expressed by the beneficiary bank's view on the basis of an interbank rejection code.
Some banks point out that the data is not currently stored in such a way as to allow such reporting.
Rejections for regulatory reasons encompass several reasons (different lists of sanctions that go beyond the European lists, compliance, etc.), which makes it difficult to provide specific details for reporting. In addition, rejections by other PSPs are not always identifiable.
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 banks are asking for further clarification on several points: the scope of transactions covered, the definition of ‘free of charge’ and the distinction between different types of customer.
Clarification is also sought on the management of charges associated with instant euro payments settled on accounts in non-euro currencies.
The reporting format must be specified (XML, csv, etc.), and concrete examples are requested for the types of charges to be reported. All technical elements relating to the declaration must be provided.
It also seems necessary to have a vision of the infrastructure for the approval phases (as well as the timetable) in order to qualify the reporting.
7. Do you perceive the reporting requirements to be proportionate? Is there information contained in the templates that is overly burdensome to report?
Overall, the requirements are perceived as disproportionate, with a high workload for certain data, particularly that on fees and rejections.
Collecting retroactive data from 2022 could be particularly tricky for some institutions. The industry will be collecting data from 1 January 2024.
The industry points out that management fees and holding fees (or service/package fees) are not relevant for monitoring changes in the costs of standard and instant transfers. The industry proposes to track the costs of transfers via its fee schedule.
8. Do you have any other comments on the reporting requirements proposed in this CP?
Given that EBA plans to finalise its specifications by the end of the year (final draft submitted to the Commission at the end of the year) and assuming that the national regulator will have to propose the data reporting format, it seems clear that the implementation schedule will be too short.
For these reasons, concerns have been expressed about the tight timetable, with some banks calling for the deadline for the first report to be extended. If the deadline of 9 April 2025 is maintained, there will be a risk to the quality of the data. In its text, the Regulation envisages a period of 10 months to organise the collection of data for these reports and to complete the necessary developments (once the specifications have been validated).
Given this slippage in the timetable (the date of June 2024 not being respected for the supply of validated specifications), it should be considered to postpone the reporting by the same amount in order to achieve the 10 months required to produce them, i.e. by the end of October 2025.
The proposed reporting format (Excel) is considered unsuitable for automation, and a more standardised format is suggested.