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?
Template 1, Items 0410 up to 0480: ‘share’ (SHA) is the only charging principle in the EEA (i.e. each user pays his/her PSP and any other option where the charges are borne by the originator or the beneficiary only are not allowed), we suggest removing these items from the reporting obligation.
Template 2, Items 0190-0220: ‘share’ (SHA) is the only charging principle in the EEA (i.e. each user pays his/her PSP and any other option where the charges are borne by the originator or the beneficiary only are not allowed), we suggest removing these items from the reporting obligation.
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?
We would like the guidelines to clarify:
- Which kind of payments accounts should be reported in 0010, 0020 and 0030 (payments accounts in euro and in EU non-euro currencies)?
- In general, reference to the PAD provisions on Transparency is needed to achieve uniformity in the reporting.
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?
We have the following comments and requests for clarification as regards the items in Annex I (reporting templates) and Annex II (instructions for PSPs):
Template S 01.00:
- Scope of credit transfers:
We assume that only credit transfers that are in scope of Regulation (EU) No 260/2012 should be reported (i.e. payment transactions carried out between and within PSPs, and payment transactions processed and settled through large value payment systems are excluded). We suggest clarifying this.
- Reporting from a PSP located in an EU non-euro country:
Annex II says on page 2 that:
“Template S 01.00 shall contain the number and value of credit transfers and instant credit transfers in euro for PSPs in euro Member States, and in national currency other than euro for non-euro Member States, unless stated otherwise in the template below”.
Concerning the reporting obligations in template S.01.00 and template S.02.00 for PSPs in EU non-euro countries, we would appreciate clarification as to whether it should be interpreted as:
- the number of euro-credit transfers and euro-instant credit transfers converted to a value in national currency using the exchange-rate (in Denmark the value of euro-transfers converted to DKK using the euro/DKK exchange-rate)
or whether it should be
- the number and value of credit transfers and instant credit transfers in national currency (In Denmark the number and value of DKK-credit transfers and DKK-instant credit transfers).
Template S 01.00, row 0250 - 0270:
This item should refer to transfers in Euro regardless of the currency of the payment account. In Denmark almost all credit transfers in euro are done from a payment account denominated in Danish kroner. We would therefore suggest that the text in row 0250-0270 should be modified as follows:
- “0250: Total number of credit transfers in Euro
Total number of credit transfers in euro. Data to be provided only where a PSP is located in a non-euro Member State”
- “0270: Total value of credit transfers in Euro
Total value of credit transfers in Euro, expressed in Euro. Data to be provided only where a PSP is located in a non-euro Member State”.
The same as above would apply to Template S.02.00, row 0110.
Template S 01.00, row 0290 – 0400: We would appreciate that the different categories of payment initiation is further clarified, i.e. an exhaustive list and a clear description of the channels is needed. Especially the difference between online banking and mobile banking should be clarified.
7. Do you perceive the reporting requirements to be proportionate? Is there information contained in the templates that is overly burdensome to report?
Although it is positive that the templates/instructions are drafted under the principle that the reporting burden on the PSPs should be limited as much as possible,
Finance Denmark believes that the draft reporting templates some places are too detailed, also in light of the sort of data that is demanded (charges etc).
Furthermore, some clarifications are needed, especially on the scope of reporting, the terminology that is used in the consultation paper, and the reporting for EU non-euro countries PSPs.
8. Do you have any other comments on the reporting requirements proposed in this CP?
We are concerned by the timetable of the ITS. If the EBA intends to submit the final draft to the Commission by the end of the year, banks really do not have enough time to implement the necessary changes to their systems for starting the reporting on 9 April 2025.