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Instant Payments

Banking and financial services

The 2020 Retail Payments Strategy highlighted the need for an EU-wide instant payments scheme. This initiative will assess the need for fostering pan-European market initiatives based on instant payments. The impact assessment will investigate whether: (i) new legislation is needed in this field; (ii) non-legislative measures would be appropriate; or (iii) other policy options are suitable.

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Public consultation

ID: 12931

Lobbying Activity

50 responses

Consultation response

Bureau Européen des Unions de Consommateurs, 2 Apr 2021

Please find attached feedback (PDF document) from BEUC the European Consumer Organization to your consultation on Instant Payments

Consultation response

EuroCommerce, 21 Dec 2022

EuroCommerce and its members welcome the proposed regulation and are keen to see instant payments in the retail environment develop into an additional fast and secure payment method. We do have some concerns and suggestions as follows: 1. We call on the Commission and other institutions to promote…

Consultation response

EuroCommerce, 31 Mar 2021

Dear Sir/Madam, Please find attached feedback from EuroCommerce with regard to your roadmap on Instant payments.

Consultation response

DIGITALEUROPE, 7 Apr 2021

DIGITALEUROPE believes the baseline policy option detailed in the inception impact assessment is the most suitable to advance instant payments today in Europe. At this stage, monitoring the market evolution and assessing the effects of voluntary efforts is the most sensible decision to foster the…

Consultation response

Fédération bancaire française, 5 Jan 2023

The French banking community welcomes the European Commission's decision to promote instant payments. However, the European Commission's text proposal on instant payments raises questions at different levels and therefore leads the French banking community to propose adjustments to the four…

European Banking Federation Seeks Market-Driven Approach to Instant Payments

European Banking Federation, 21 Dec 2022

The federation opposes mandatory instant payment offerings through all channels, arguing banks should maintain freedom to determine their product offerings. They request legal requirements be limited to mandating sending for single payments through online channels and mandating reachability. They strongly object to price regulation, arguing instant payments have higher costs than regular transfers and competition should determine pricing.
Banks could avoid mandatory 24/7 infrastructure investments and recover higher operational costs through differentiated pricing.
Consumers and small businesses lose guaranteed access to instant payments at affordable prices.

Banking Federation Seeks Market-Led Approach to EU Instant Payments

European Banking Federation, 7 Apr 2021

The federation urges a market-driven approach to instant payments adoption rather than mandatory regulation. They request sufficient implementation time if adherence is mandated, and call for a stable regulatory environment supporting value-added products. They oppose price regulation for instant payments.
This would avoid mandatory compliance costs and preserve banks' ability to charge market rates for instant payments.
Consumers and merchants lose potential cost savings from regulated instant payment pricing and mandatory adoption.

Consultation response

Mastercard Europe, 6 Apr 2021

Mastercard welcomes the opportunity to feedback on the Commission’s initiative on instant payments. Electronic payments are the foundation of the digital economy in Europe. We see the importance of giving consumers and businesses access to the full range of electronic payment types including cards,…

Consultation response

Bitkom e.V., 3 Jan 2023

Bitkom welcomes the Commissions proposal to accelerate the rollout of instant payments as an opportunity to drive further innovation in payment services. We appreciate the opportunity to provide feedback on the proposed regulation. Our preliminary position paper lays out our ideas on how the draft…

Consultation response

Intesa Sanpaolo, 29 Dec 2022

Intesa Sanpaolo, one of the top banking groups in the European Union, welcomes the opportunity to provide preliminary feed-back to the co-legislators about the European Commissions proposal for an Instant Payment Regulation. As highlighted in other European Commissions public consultations, Intesa…

Consultation response

BANCO BILBAO VIZCAYA ARGENTARIA, 23 Dec 2022

We would like to thank you the European Commission for the opportunity to provide feedback on this proposal for a Regulation. In the attached document you can find our detailed comments on the proposal

Consultation response

Asociación Española de Banca, 4 Jan 2023

The Spanish Banking Association (AEB in its acronym) welcomes the opportunity to provide comments in the context of the public participation process on the Regulation amending the SEPA Regulation and the Regulation on cross-border payments as regards instant credit transfers. In line with the…

Consultation response

Asociación Española de Banca, 7 Apr 2021

The Impact Assessment establishes several objectives: "making cross-border payments easier, faster and cheaper", "ensuring citizens and companies have high quality, secure and cost-efficient payment solutions to make all their payments, both domestically and cross-border”, "reduce fragmentation in…

Consultation response

Finance Denmark, 22 Dec 2022

Se attached file.

Consultation response

Bundesverband der Deutschen Volksbanken und Raiffeisenbanken, 7 Apr 2021

The National Association of German Cooperative Banks (BVR e. V.) is the umbrella association of the cooperative banking sector in Germany. The “Volksbanken Raiffeisenbanken Cooperative Financial Network” (Genossenschaftliche FinanzGruppe Volksbanken Raiffeisenbanken) is the Cooperative Banking…

Consultation response

ING Group, 7 Apr 2021

ING fully subscribes the importance of instant payment for the EU internal market. We believe it is crucial to process payments – both national and cross-border within the SEPA area - for citizens and companies in Europe in a real-time, reliable, cost-efficient and secure way as backbone for…

Consultation response

European Association of Co-operative Banks, 7 Apr 2021

Attached please find findings from the survey performed among our member organizations.

Consultation response

Ingka Services A.B., 6 Apr 2021

Since 2018, Ingka Group, the strategic partner in the IKEA franchise system, has embarked on a journey to transform into a retailer fit for the 21st century. We are becoming an omnichannel retailer, using payment solutions to meet customers wherever and whenever they choose, with the products and…

Consultation response

European Savings and Retail Banking Group, 7 Apr 2021

ESBG and its Members fully support efforts to increase the uptake of SCTInst and share the view that it could facilitate stronger and more integrated homegrown pan-EU payment solutions. The EC should foster an environment that enables the uptake of instant payments, e.g. by favoring market-led…

Consultation response

CAISSE DES DEPOTS, 7 Apr 2021

Feedback on the European Commission (EC) ’s Roadmap (Inception Impact Assessment) on Instant Payments in the EU This feedback emanates from the Group Caisse des Dépôts which already answered to the European Commission ‘s consultation on a retail payments strategy for the EU. A. Context, problem…

Consultation response

Finance Sweden, 4 Jan 2023

Please find attached the response from the Swedish Bankers' Association.

Consultation response

Society for Worldwide Interbank Financial Telecommunication, 7 Apr 2021

To achieve truly functional instant payments across Europe it is important to have interoperability at the heart of any new system, to ensure compatibility and to prevent barriers that could hamper the effectiveness of such a scheme. When designing an Instant payments scheme there should be a dual…

Consultation response

American Express Corporation, 7 Apr 2021

American Express supports the initiatives by the Commission encourage instant payments across the EU. The design of such initiatives should consider all possible barriers to instant payments to ensure further adoption by consumers and businesses alike. A more developed instant payments…

Consultation response

Wise Ltd, 7 Apr 2021

Wise welcomes the opportunity to provide feedback on the European Commission’s initiatives on instant payments. We were heartened to see instant payments becoming a true pillar of the Commission’s Retail Payments Strategy and applaud the ambition to make instant payments the norm across the EU.…

Consultation response

Die Deutsche Kreditwirtschaft, 4 Jan 2023

GBIC welcomes the opportunity, provided by the European Commission, to give feedback on this proposal for a Regulation and contribute to the legislative debate. Please find attached our detailed comments and positions on the proposal.

Consultation response

Die Deutsche Kreditwirtschaft, 7 Apr 2021

We would like to express our concern that the first part of the consultation on Instant Payments (targeted consultation) was published before the end of the deadline for feedback on the Impact Assessment. The SEPA Instant credit transfer ("Instant Payments/ SCT Inst") is an important enrichment of…

Consultation response

Febelfin, 4 Jan 2023

Febelfin welcome the proposal for legislating instant credit transfers (SCT Inst). SCT Inst are an important building block of the future EU payments market. Statistics show SCT Inst are already widely adopted and offered in Belgium. Today about half of Belgian institutions offering credit…

Consultation response

Bureau Brussels Consulting, 19 Dec 2022

ACCIE welcomes the Commissions proposal on Instant Payments (IPs), which will help increase consumer choice regarding preferred payment methods. ACCIE appreciates that the proposal addresses consistency with existing legislation such as PSD2 and the Regulation on Cross-Border Payments. ACCIE…

Consultation response

DATEV eG, 6 Apr 2021

DATEV eG welcomes the opportunity to provide feedback on the European Commission’s Inception Impact Assessment on an initiative on instant payments in the EU. DATEV approves the EU Commission’s intention to foster SEPA Instant Payments in order to strengthen the Single Market of financial services…

Consultation response

Bizum, 3 Jan 2023

Bizum welcomes the opportunity, provided by the European Commission, to give feedback on this proposal for a Regulation and contribute to the legislative debate. Please find attached our detailed comments on the proposal.

Consultation response

European Third Party Providers Association, 3 Jan 2023

ETPPA welcomes the European Commissions legislative proposal for a regulation on instant payments. A regulation to secure the wide-spread availability of instant payments has long been a missing brick in the PSD2 ecosystem. We believe there has been a clear need for swift legislation in order to…

Consultation response

European Third Party Providers Association, 7 Apr 2021

ETPPA, the European trade association of bank-independent Third Party Providers (TPPs) under PSD2, very much welcomes the EC’s initiative in promoting instant payments and its Inception Impact Assessment, which we hereby would like to comment on: We fully agree that instant payments shall become…

Consultation response

Payments Europe, 6 Apr 2021

Please see attached paper in which Payments Europe recommends that with this Inception Impact Assessment, the EC pursues the proposed baseline option (1), which includes monitoring the market evolution and assessing the effects of voluntary efforts to put forward initiatives delivering on the above…

Consultation response

European Payment Institutions Federation, 7 Apr 2021

EPIF welcomes the opportunity to provide our views to the Commission Inception Impact Assessment on Instant Payments. We would like to take this opportunity to share with you some general comments that our members have on this issue. We agree with the Commission’s overall objective to foster…

Consultation response

Bernstein Public Policy, 7 Apr 2021

Please find attached general feedback on the Roadmap on behalf of DKB, with 4.6 million clients and 4.500 employees one of Germany's largest banks, to be complemented by more specific responses to the recently launched targeted and public consultations on instant payments.

Consultation response

Electronic Money Association, 5 Jan 2023

The EMA welcomes the Commissions proposals to improve the supply of instant payments across Europe, and tackle the key issues that have hampered the uptake of instant payment in euro. We share the Commissions view that SEPA instant payments have the capacity to form the foundations to support the…

Consultation response

Association of Credit Card Issuers in Europe, 6 Apr 2021

The Association of Credit Card Issuers Europe (ACCIE) is pleased to submit commentary on the roadmap on instant payments, and would like to bring to the Commission’s attention the following points: - Instant payments should be considered complementary to other payment methods, as different payment…

Consultation response

European Digital Finance Association, 5 Jan 2023

European Digital Finance Association and its members representing thousands of fintechs throughout Europe welcome the proposed regulation to cater for speed in payment transfers in the consumer perspective. We acknowledge the fact that the financial system is not able to provide instant payments to…

Consultation response

CBI S.c.p.a Società Benefit, 28 Dec 2022

Comments in the attached document.

Consultation response

Asociación Nacional de Establecimientos Financieros de Crédito (ASNEF), 27 Dec 2022

Por la presente se adjuntan los comentarios de ASNEF (nº de Registro de Transparencia 11218815591-29) relativos a la propuesta de Reglamento sobre transferencias inmediatas y, en concreto, en relación con los Artículos 5 quáter, apartado 1 y 5 quinquies, apartado 3. -------- Please find enclosed…

Consultation response

Trustly Group AB, 7 Apr 2021

Please find attached feedback (PDF document) from Trustly Group AB to your consultation on Instant Payments.

Consultation response

YUTA - national association of travel agencies in Serbia, 5 Jan 2023

YUTA sector, within MonTiN Safe administration, has recognized instant payment as a very important instrument for integration of the multimodal traveling, central international currency exchange, removing fragility in functioning of the linked business processes (which is very important for tourism…

Consultation response

Verband der Auslandsbanken in Deutschland e.V. / Association of Foreign Banks in Germany, 5 Jan 2023

Please find attached the Position Paper of the Association of Foreign Banks in Germany of 5 January 2023 on the Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL amending Regulations (EU) No 260/2012 and (EU) 2021/1230 as regards instant credit transfers in Euro.

Consultation response

Associação Portuguesa para a Defesa do Consumidor, 21 Dec 2022

DECO, the Portuguese Consumer Protection Association, welcomes the proposal for a Regulation on Instant payments (IPs). To achieve a widespread take up of IPs, especially from consumers, it is crucial to have a regulatory framework making them available, accessible, and secure. To that end, we…

Consultation response

ASSOCIAZIONE NAZIONALE CONSULENTI FINANZIARI, 20 Dec 2022

Dear Commission, in accepting the invitation in the consultation paper on the Proposal for a regulation of the European Parliament and of the Council on amending Regulations (EU) No 260/2012 and (EU) 2021/1230 as regards instant credit transfers in euro, ANASF - National Association of Financial…

Consultation response

Association Française des Trésoriers d'Entreprise, 7 Apr 2021

L’AFTE, Association des Trésoriers d’Entreprise, salue l’initiative de la Commission Européenne de promouvoir les paiements instantanés à l’échelle européenne et de solliciter les avis des différents acteurs du marché. Déjà fortement mobilisée avec ses adhérents sur le sujet, l’AFTE est favorable…

Consultation response

Smart Payment Association, 7 Apr 2021

The Smart Payment Association (SPA) s an organization of major european security technology vendors for the financial industry. SPA is particularly active in the production of both SEPA and Global standards for retail payment systems with a focus on innovation and consumer protection. Our…

Consultation response

Global Institute for Structure relevance, Anonymity and Decentralisation i.G., 7 Apr 2021

>>Herausforderungen: GISAD begrüßt die Initiative der Europäischen Kommission, Sofortzahlungen zu vereinheitlichen. Bei den gesetzlichen Regelungen sollten bereits die neuen Möglichkeiten im Rahmen der Einführung eines EU-D-S Berücksichtigung finden. Bargeld wird in vielen Fällen heute noch…

Consultation response

Verband der Auslandsbanken in Deutschland e.V. / Association of Foreign Banks in Germany, 7 Apr 2021

Dear Sir or Madam, We appreciate the opportunity to provide input to the inception impact assessment document Ares(2021)1648321 on Instant Payments. Please find enclosed our position paper of 7 April 2021 concerning the following topics: (i) Directive or Regulation (ii) Implications of mandatory…

Consultation response

Federimpreseitalia Associazione Datoriale della PMI, 12 Mar 2021

Attualmente il bonifico istantaneo comporta un costo che può variare , a seconda dell'istituto bancario da pochi centesimi fino a oltre 3 euro a operazione, in quanto non tutte le banche aderiscono all'accordo europeo. Riteniamo che il costo del progresso e l'innovazione dovrebbe essere un fattore…