The SFC supports the objectives of the European Commission’s proposal (COM(2022) 546 final) to amend the SEPA Regulation as regards instant credit transfers in euro to further encourage the uptake of instant payments by payment service providers (PSPs) and payment service users (PSUs). Instant payments can enhance customers’ experience, contribute to further digitalisation of the payments sector and provide innovative solutions that can make Europe more competitive globally if it is offered in a secure way that also respects customers’ privacy.
Making instant payments the new normal however requires the scope of the proposed Regulation to be proportionate to the objective pursued, by notably excluding certain types of PSPs, client segments and client channels from the mandatory sending of instant payments. Some adjustments are also needed to reflect the further investment that is necessary to operate the infrastructure changes and to ensure the highest level of compliance when it comes to sanctions screening. For all these reasons, an extension of the implementation timelines is of the essence.
The SFC believes that a market-led approach would better contribute to the further uptake of instant payments. Additionally, a fair compensation mechanism and the protection of banks’ customers’ data are key success factors for a widespread adoption of instant payments and the establishment of a level-playing field with fintech and big tech companies acting as third-party providers.
Finally, in our view, the proposed Regulation does not affect the continuing participation of non-EEA countries in SEPA and their PSPs’ continuing eligibility for participation in SEPA, including in the SEPA Instant Credit Transfer (SCT Inst) scheme.
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