The draft implementing technical standards aim to establish uniform reporting templates for payment service providers (PSPs) under the SEPA regulation. These standards will provide information on charges related to credit transfers and payment accounts, as well as on rejected transactions. The goal is to ensure a robust analysis of the impact of the SEPA regulation on pricing while avoiding an excessive reporting…
- Title: Draft Implementing Technical Standards on uniform reporting under SEPA
- Author: European Banking Authority (EBA)
- Date: 2025
- Type: technical standard (Implementing Technical Standards - ITS)
- Scope: harmonized reporting of charges on transfers (credit, instant), payment accounts, and shares of transactions rejected related to targeted financial restrictive measures in the European Union
- Population concerned: payment service providers (PSPs) in the European Union
- Sector: payment services, SEPA regulation
- Period covered: data from 26 October 2022, with first annual reports expected from 2026
- Partial document: only the first 34 pages out of 50 provided
The document presents the final draft of the implementing technical standards (ITS) developed by the EBA to harmonize PSP reporting to national competent authorities (NCAs) on charges applied to transfers (credit and instant), payment accounts, as well as on the share of instant transactions rejected due to the EU's targeted financial restrictive measures (p. 3-4).
This reporting is mandated by Article 15 of the SEPA regulation amended by the Instant Payment Regulation (IPR) of 2024. The objective is to provide the European Commission (EC) with robust data to analyze the evolution of charges and the impact of restrictive measures on instant payments, aiming for a report to be presented to the European Parliament and the Council by October 2028.
The ITS draft defines detailed reporting models with breakdowns by transfer type (national, cross-border), user type, payment initiation channel, and charged party. It also includes data on payment accounts, including maintenance fees and total charges, as well as on instant transaction rejections related to sanctions.
The EBA sought a balance between the need to obtain comprehensive data for reliable analysis and minimizing the reporting burden for PSPs. It relies on existing terminologies and methodologies (PSD2, PAD, ECB payment statistics regulation) to avoid unnecessary redundancies.
The public consultation (July-October 2024) revealed major concerns about the practical impossibility of meeting the initial reporting deadline of 9 April 2025, as the ITS, taxonomies, and validation rules will not be adopted or published by then, rendering data incomplete and non-harmonized. The EBA therefore recommends postponing harmonized collection to 9 April 2026, with transmission to the EC and EBA in October 2026, and not sanctioning PSPs not reporting in 2025.
The document also details adjustments made to reporting models to clarify the distinction between charges of the payer PSP and the beneficiary PSP, consideration of currency transfers in non-euro states, and alignment with ECB standards.
Finally, the EBA plans to publish by Q2 2025 the XBRL taxonomy, data point model, and validation rules, essential for implementing the reporting.
Key recommendations:
- Postpone harmonized collection to 9 April 2026 to avoid unnecessary burden in 2025
- Harmonize PSP-NCA and NCA-EC/EBA reports
- Clarify and simplify reporting models and instructions
- Rely on existing standards to avoid duplication
- Ensure collection of detailed but proportionate data to enable robust analysis of charges and rejections related to restrictive measures (p. 3-5)
- The Instant Payment Regulation (IPR) of March 2024 amends SEPA Regulation (EU) No 260/2012 to require PSPs to offer instant transfers at the same tariffs as classic transfers, and to perform daily user checks against sanctions lists (p. 5).
- Article 15(3) of the SEPA regulation mandates annual reporting of charges on transfers, payment accounts, and shares of rejections related to targeted financial restrictive measures (TFRM).
- Article 15(5) mandates the EBA to develop ITS specifying uniform reporting models, instructions, and methodologies from PSPs to national authorities.
- The objective is to provide the European Commission with reliable data to assess the impact of the SEPA regulation on payment service prices and the effectiveness of restrictive measures, with a report expected no later than 9 October 2028.
- The scope covers only credit transfers (instant and classic) within the Union, in euro for euro-area PSPs, and in national currency and euro for PSPs outside the euro area.
- Limitations include exclusion of other payment types (direct debits, cards), and practical difficulty in meeting the first reporting deadline in April 2025 (p. 5-11).
- The public consultation gathered 38 responses, raising concerns about feasibility, clarity of definitions, data duplication, and data scope (p. 6-7, 21-34).
Reporting and deadlines:
- The SEPA regulation imposes a first reporting by 9 April 2025, covering the period since 26 October 2022 (p. 6).
- The EBA highlights the practical impossibility of meeting this deadline as the ITS, taxonomies, and validation rules will not be adopted or published in time, and the industry will need 12 months to implement these standards (p. 3-4, 6).
- Recommendation to postpone harmonized collection to 9 April 2026, with transmission to the EC and EBA in October 2026, and not sanction PSPs not reporting in 2025 (p. 4, 23).
Harmonization and duplication:
- Reporting relies on existing terminologies and approaches from PSD2, PAD, and ECB payment statistics regulation to avoid creating new definitions (p. 3, 8, 26).
- Some required data may already be reported in other frameworks (e.g., total number of transfers), but exemptions in the ECB regulation necessitate specific reporting to cover all PSPs (p. 7, 24-25).
- NCAs may authorize PSPs to reference data already submitted to avoid duplication (p. 7).
Data breakdown:
- PSPs must provide data on transfer charges (instant and classic) with breakdowns by transfer type (national, cross-border), user type (consumers, non-consumers), initiation channel (online, mobile, paper), and charged party (payer PSP and beneficiary PSP) (p. 3, 9, 26-27).
- Breakdown by initiation channel is maintained as charges often vary by this criterion (p. 26).
- Reporting of beneficiary PSP charges is simplified, requiring only number, value, total charges, and distinction between free or paid transfers, to limit reporting burden (p. 27).
Payment accounts:
- PSPs must report charges related to payment accounts, including maintenance fees and total charges, according to PAD definitions and client information documents (FID, SoF) (p. 9-10, 30-31).
- Instructions specify how to calculate these charges, especially for PSPs not providing SoF (p. 10, 30).
- Scope covers all accounts used for SEPA transfers, without distinction between consumers and other PSUs (p. 28-29).
Transaction rejections:
- PSPs must report the share of instant transactions rejected due to targeted financial restrictive measures (TFRM), distinguishing national and cross-border, and actions of the payer PSP and beneficiary PSP (p. 3, 10-11, 31-34).
- Reporting includes rejections before and after the entry into force of daily control requirements (p. 31-32).
- PSPs must also report cases of funds frozen before or after transfer (p. 10-11, 31-33).
- Only rejections related to measures adopted under Article 215 TFEU are included, excluding other reasons or foreign lists (p. 33).
Models and formats:
- Data must be submitted according to uniform models defined in Annex I and II, with precise numeric formats (e.g., amounts in thousands of units, integers without decimals) (p. 14).
- Reporting is done at entity level, branches reporting to the NCA of their host country, headquarters to the NCA of the home country (p. 13).
Impact and balance:
- The EBA evaluated different options for data frequency and detail (e.g., daily data vs annual aggregates), favoring annual aggregated reporting to limit burden (p. 17-19).
- Regarding products, a compromise is found between detailed reporting of packages and aggregated reporting of charges, distinguishing maintenance and total charges (p. 18-19).
- The cost-benefit analysis concludes that the benefits of robust analysis of SEPA regulation effects justify reporting costs (p. 19).
Public consultation:
- 38 responses received, with major concerns on deadlines, duplication, clarity of definitions, data scope, and methodology for rejection calculation (p. 21-34).
- The EBA incorporated changes to clarify definitions, adjust models, and recommend deadline postponement (p. 23-34).
- Established facts:
- The amended SEPA regulation imposes annual reporting of charges and rejections related to transfers and payment accounts (p. 5-6).
- The EBA developed ITS defining uniform models and instructions for this reporting (p. 3, 12-15).
- Reporting must cover credit transfers within the Union, in euro or national currency depending on the country, with detailed breakdowns (p. 3, 9, 13).
- PSPs must report both payer PSP and beneficiary PSP charges, with an adapted level of detail (p. 27).
- Reporting includes the share of rejections related to targeted financial restrictive measures, distinguishing actions of payer and beneficiary PSPs (p. 10-11, 31-33).
- Assumptions:
- The EBA assumes PSPs do not frequently change their tariffs, justifying annual aggregated reporting rather than daily (p. 17).
- Annual aggregated data allow robust analysis while limiting burden (p. 17-19).
- PSPs can reference data already submitted in other frameworks to avoid duplication (p. 7).
- Interpretations:
- Postponing the first harmonized reporting to 2026 is necessary to ensure data quality and consistency (p. 4, 23).
- Breakdown by initiation channel is relevant as charges vary by this criterion (p. 26).
- Reporting charges on payment accounts must distinguish maintenance fees and total charges to reflect product diversity (p. 30-31).
- Distinction between payer and beneficiary PSP in charge reporting is justified by the difficulty for a PSP to know charges applied by the other party (p. 27-28).
- Uncertainties:
- PSPs’ capacity to provide detailed historical data dating back to 2022 is limited (p. 23-24).
- Product variability and national practices may complicate data comparability (p. 9-10, 30).
- The actual impact of restrictive measures on transaction rejections remains to be analyzed from collected data (p. 11).
- Reporting burden remains an issue despite harmonization and simplification efforts (p. 19, 23).
- The EBA concludes that the final ITS draft meets the legal mandate of Article 15 of the amended SEPA regulation by defining models and instructions enabling harmonized and robust reporting of charges and rejections related to transfers and payment accounts (p. 3, 19).
- Harmonized reporting cannot be carried out in 2025 without causing disproportionate burden and insufficient data quality; postponing harmonized collection to 9 April 2026 with transmission to the EC and EBA in October 2026 is therefore recommended (p. 4, 23).
- National authorities should discourage non-harmonized reports in 2025 and not sanction PSPs not reporting that year (p. 4).
- The EBA will develop by Q2 2025 the XBRL taxonomy, data point model, and validation rules necessary for implementing the reporting (p. 4).
- Reporting must be done at entity level, with branches reporting to the NCA of the host country, to ensure geographic data accuracy (p. 13).
- Models and instructions have been adjusted to clarify definitions, reduce duplication, and adapt data breakdowns (p. 23-34).
- The EBA also recommends harmonizing NCA reporting to the EC and EBA, although this is outside the ITS scope (p. 6, 13).
- Overall, the cost-benefit analysis shows that the advantages of harmonized and robust reporting justify costs for PSPs and authorities (p. 19).
- These conclusions call for a progressive and coordinated implementation to ensure data quality and regulatory compliance.
Synthesis note written from the full document by DataSAI Academy. This note comes from the scientific library of the DataSAI Academy, open to all.