Comparing the new CESOP Q&A with the previous version
The European Commission just published an updated version of its CESOP Q&A. The document’s purpose is to complement the CESOP guidelines with a number of Frequently Asked Questions that provide practical information and explanations on the reporting of payment data by payment service providers and on their collection by Member States.
As CESOP approaches and PSPs are getting ready to successfully tackle this new regulatory challenge, we’ve crafted a document comparing the July and November versions of the Q&A.
In question 3.1.2, further clarifications are again provided on the identifiers to be used (IBAN, BIC, others) to determine the location of the payee/payer. The European Commission reaffirms that the indicator or identifier to be used must be that which best reflects the actual location of the payee or payer. Each payment service provider will need to analyze its own processes and payment products to determine which indicator(s) to use that best reflects the actual location of the payee or payer. It is recommended that the payment service provider documents this analysis and the conclusions made for further reference. While IBAN can be considered as a good indicator to use for the location of the payer/payee in case of bank transfer, for other types of payment transactions however, if a payment service provider has different indicators available which provide a more accurate location of the payee or payer, the PSP must choose the identifier that, in its specific situation, best reflects the actual location of the payee and payer. The obligation forbids payment service providers which have access to multiple identifiers to use only those that give a less accurate location of the payer or payee for the purpose of simplifying where the reporting obligation should occur.
Two new questions have also been added to the Q&A:
- 3.2.6: Where the payee has branches in several countries, and each branch has a separate payment account, do these branches need to be considered as separate payees (with their respective location) or as one payee together with the head office (and one location, i.e., of the head office) for the aggregation rule?
- 4.19: Should a refund be reported if the original payment was not reported?
Read the Q&A document, which includes a comparison with the July version
Moreover, the European Commission also updated the CESOP Guidelines. They are available HERE.
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The consolidated version of the Q&A was created by the LUXHUB team for information purposes only. The sole authorative version is the published on the European Commission’s website.