EU commission clarifies verification of payee requirements
The instant payments regulation includes several elements, including reception and initiation of instant credit transfers, verification of payee as well as the modification of sanctions screening obligations, LUXHUB’s Anne-Sophie Morvan told Delano, pointing out some of the clarifications related to verification of payee and other topics.
The European Commission on 23 July 2024 published clarifications around the requirements of the instant payments regulation (IPR). In this series, we asked industry experts in Luxembourg about their key takeaways from the list of Q&As. Here’s what Anne-Sophie Morvan, chief commercial officer at LUXHUB, highlighted for us.
Large value payment systems (LVPS)
“One question that was agitating the banking scene over the last months was related to the applicability of the Instant Payments Regulation, or not, to transactions processed and settled via large value payment systems or LVPS (such as T2),” said Morvan. “The answer to this question was particularly important for some banks, which are solely processing credit transfers through these channels and, for several of them in Luxembourg, with very limited volume of payments (but large amounts).”
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Verification of payee (VOP)
“As from 9 October 2025, payment service providers performing SEPA payments will have to offer their payers a service ensuring verification of the payee to whom this payer intends to send a credit transfer,” explained Morvan. “Over the last months, several institutions argued that internally processed payments, credit transfers which can solely be performed from and to accounts held by the accountholder itself as well as payments processed for the benefit of authorised beneficiaries could / should fall out of the scope of the VOP obligation since they might seem to present less risks at first sight. DG Fisma nevertheless confirmed in answers n°92, n°93 and n°133 that payers shall benefit from the service ensuring verification for ‘on-us’ and ‘me-to-me’ transfers, as well as in the case of transfers initiated to authorised beneficiaries.”
Bulk payments
“Furthermore, bulk payments raise a lot of questions as the number of checks per file to be performed might often average tens of thousands or even much more, for instance when it comes to the payment of civil servants’ salaries. Professionals may decide to opt out from the verification of payee but at any moment they should have the possibility to opt in again. Several questions were therefore raised in this respect in order to find practical solutions to this challenge.”
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