Draft Implementing Technical Standards on uniform reporting under SEPA - Annex II - Instructions

General Information

The document is a draft Implementing Technical Standards published by the European Banking Authority (EBA) in 2025. It concerns uniform reporting under SEPA (Single Euro Payments Area) related to payment services. The scope covers payment service providers (PSPs) in the European Union member states, whether in the euro area or outside it. The document details instructions for completing six reporting templates concerning: the number and value of transfers (classic and instant), associated fees, the number of payment accounts, as well as rejected instant transactions. The reference period is defined by each PSP for its periodic reports. The main legal framework is Regulation (EU) No 260/2012 (SEPA Regulation) and related regulations on payment statistics (notably ECB/2013/43). The document comprises 17 pages and is addressed to PSPs subject to these reporting obligations.

Executive Summary

This draft Implementing Technical Standards aims to standardize reporting by payment service providers (PSPs) in the European Union under the SEPA framework. It is essential as it ensures consistency, comparability, and transparency of data related to transfers (classic and instant), applied fees, payment accounts, and transaction rejections, thus facilitating regulatory supervision and payment market analysis. The main findings are that reporting must cover both national and cross-border transfers, in euro and in national currencies of non-euro area states, with precise distinctions according to client type, transfer nature (instant or not), initiation mode (online, mobile, paper), and charging (free or paid). Charges must be reported in the transaction currency, excluding conversion fees. Reporting also includes the number of payment accounts and total associated fees, as well as cases of instant credit transfer rejections related to targeted financial restrictive measures. The conclusions emphasize the need for rigorous application of instructions to ensure data quality. Recommendations stress compliance with legal definitions, correct currency conversion according to ECB rates, and clear distinction of data categories. This framework will allow national and European authorities to better monitor payment flows and ensure regulatory compliance (p. 1-17).

Context and Objectives

This document was developed to specify reporting modalities for PSPs pursuant to Article 15 of the SEPA Regulation (EU) No 260/2012. The objective is to provide detailed instructions for completing the six reporting templates, to ensure harmonized and comprehensive data collection on transfers, fees, accounts, and instant transaction rejections. The regulatory context requires PSPs in member states, whether in the euro area or not, to periodically transmit these data to competent national authorities (NCA). The issues relate to effective payment monitoring, cost transparency for users, and detection of blockages linked to restrictive financial measures. The document also specifies limits, notably exclusion of conversion fees and transactions outside the Union, as well as cases where NCAs may authorize sending references to already submitted data (p. 2-3).

Summary of Key Points by Theme

Transfer reporting: Reporting distinguishes classic and instant transfers, sent and received, in euro for PSPs in the euro area, and in national currency for PSPs outside the euro area (S 01.01). Data must be broken down by free of charge, client type (consumer or professional), national or cross-border nature, and initiation mode (online, mobile, paper). Electronically initiated transfers include files/batches, counted individually (p. 3-9).

Euro transfer reporting for PSPs outside the euro area: Template S 01.02 covers only the number and value of euro transfers, without further breakdown (p. 9-10).

Fee reporting: Template S 02.01 covers fees charged to users for sent and received transfers, with breakdowns similar to transfer reporting (national/cross-border nature, client type, initiation mode). PSPs outside the euro area use template S 02.02, which does not provide for breakdowns (p. 10-13).

Payment account reporting: Template S 03.00 records the total number of payment accounts and total annual fees associated, expressed in local currency or euro according to PSP location. Fees include costs related to account services, including prepaid packages, but exclude currency conversion fees. The number of accounts is that at the end of the reference period (p. 13-15).

Instant transfer rejection reporting: Template S 04.00 records the number of instances where instant transfers were rejected or funds frozen due to targeted financial restrictive measures (TFRM). Data are broken down by PSP role (payer or beneficiary) and national or cross-border nature of transfers. This reporting aims to ensure traceability of blockages related to financial sanctions (p. 15-17).

Currency conversion: Fees must be reported in the transaction currency, with conversion according to ECB reference rates if necessary. Currency conversion fees are excluded from reporting (p. 2, 10, 14).

Main Findings and Lessons Learned

Findings: The document specifies six mandatory reporting templates for PSPs, with detailed instructions on data to collect and their breakdown, in accordance with the SEPA Regulation. It clearly establishes legal definitions to comply with, currency conversion methods, and exclusions (notably conversion fees and transactions outside the Union). PSPs must provide data on sent and received transfers, charged fees, payment accounts, and rejections related to restrictive financial measures.

Assumptions: The document assumes PSPs have information systems capable of distinguishing transaction categories (instant, national, cross-border, initiation modes) and calculating fees according to definitions. It is also assumed that national authorities may accept references to previously submitted data in some cases.

Interpretations: The EBA interprets that this detailed reporting will allow better monitoring of payment flows, precise cost analysis for users, and effective detection of blockages related to sanctions. Distinguishing initiation modes and client types aims to better understand payment behaviors.

Uncertainties: The document does not address precise modalities for quality control of transmitted data nor sanctions in case of non-compliance. It leaves some discretion to national authorities to adapt requirements (e.g., acceptance of references to prior data).

Conclusions and Recommendations

The EBA concludes that rigorous implementation of these instructions is essential to guarantee quality and uniformity of data collected on SEPA payments. It recommends PSPs strictly comply with legal definitions, data breakdown modalities, and specified currency conversion rules. The document stresses the importance of excluding conversion fees and clearly distinguishing instant transfers from others. National authorities are invited to apply these standards and may, under conditions, authorize sending references to already submitted data to avoid redundancies. This framework will improve payment monitoring, cost transparency, and detection of blockages related to financial restrictive measures (p. 1-17).