COMMISSION STAFF WORKING DOCUMENT 1st implementation report on the SEPA Roadmap for 2009–2012   Accompanying document to the   REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL  establishing technical requirements for credit transfers and direct debits in euros and amending Regulation (EC) No 924/2009  (Text with EEA relevance)
Date: 2010-12-16
Institutions: European Commission
Subjects: bank charges, capital transfer, credit transfer, electronic money, financial legislation, intra-EU payment

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EUROPEAN COMMISSION 

Brussels, 16.12.2010 
SEC(2010) 1585 final 

COMMISSION STAFF WORKING DOCUMENT 

1st implementation report 
on the SEPA Roadmap for 2009–2012 

Accompanying document to the 

REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL 

establishing technical requirements for credit transfers and direct debits in euros and 
amending Regulation (EC) No 924/2009 

(Text with EEA relevance) 

SEC(2010) 1583 final 
 SEC(2010) 1584 final 
 COM(2010) 775 final 

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COMMISSION STAFF WORKING DOCUMENT 

1st implementation report 
on the SEPA Roadmap for 2009–2012 

Accompanying document to the 

REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL 

establishing technical requirements for credit transfers and direct debits in euros and 
amending Regulation (EC) No 924/2009 of the European Parliament and of the Council 

(Text with EEA relevance) 

1. 

INTRODUCTION 

On 10 September 2009, the European Commission published its Communication Completing 
SEPA: a Roadmap for 2009–20121. 

The SEPA Roadmap details the work that still has to be accomplished in order to successfully 
reap the full benefits of the Single Euro Payments Area (SEPA)2. The SEPA project is fully in 
line with the Europe 2020 strategy which aims at a smarter economy where prosperity results 
from innovation and from more efficient use of available resources. 

The key reason that led the European Commission to establish the SEPA Roadmap remains 
valid: uncertainty still prevails on the payment supply and demand side as regards the future 
of  SEPA,  resulting  in  a  slow  pace  of  migration  to  SEPA  products.  This  uncertainty  is 
exacerbated  by  the  aftermath  of  the  financial  crisis.  The  current  adverse  economic  climate 
induces  a  very  cautious  approach  to  further  SEPA  investments  by  some  payment  service 
providers  (mostly  banks)  and  by  high-volume  payment  users  (mainly  businesses  and  public 
administrations). 

Despite  repeated  calls  for  swift  migration  from  EU  institutions  and  continuous  political 
support for the SEPA project, actual migration from existing national payment instruments to 
the core SEPA payment instruments is still lagging behind expectations and mainly limited to 
cross-border transactions. 

Both  the  European  Parliament  in  a  recent  Resolution3  and  the  ECOFIN  Council  in  its 
December  2009  conclusions4  therefore  specifically  welcomed  the  initiative  of  the  SEPA 
Roadmap. 

1 
2 

3 

http://ec.europa.eu/internal_market/payments/docs/sepa/com_2009_471_en.pdf 
In  geographical  terms,  SEPA  currently  comprises  the  27  EU  Member  States,  Iceland,  Liechtenstein, 
Norway, Switzerland and Monaco. 
http://www.consilium.europa.eu/uedocs/cms_data/docs/pressdata/en/ecofin/111670.pdf 

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The  SEPA  Roadmap  commits  the  Commission  to  closely  monitor  its  implementation  by  all 
identified  stakeholders  and  publish  regular  progress  reports.  This  first  report  contains 
an assessment  of  the  progress,  direction  and  results  achieved  since  the  publication  of  the 
SEPA Roadmap. It and also provides a detailed breakdown of the state of play concerning the 
separate action points with potential follow-up actions. 

2. 

PRIORITY 1: FOSTER MIGRATION 

Migration  is  defined  as  the  transition  period  during  which  new  SEPA  instruments  and  old 
(legacy)  payment  instruments  co-exist  in  the  market.  This  is  currently  the  case  for  credit 
transfers and direct debits since the SEPA credit transfer (SCT) and SEPA direct debit (SDD) 
schemes have been launched by the European Payments Council (EPC) on 28 January 2008 
and 2 November 2009 respectively. 

2.1. 

An active role for public authorities 

Public  administrations  (PA)  make  20–25 %  of  all  electronic  payments  in  the  EU.  They 
therefore have a crucial role to play in the migration process to SEPA products, especially for 
credit transfers and direct debits.  

Due to the significant number of PA in each Member State, migration can be organised much 
more  effectively  if  it  takes  place  in  a  coordinated  and  synchronised  matter.  The  ECOFIN 
Council stressed the need for such coordination in the form of a common, national migration 
plan  for  all  PA.  Currently,  such  a  plan  has  only  been  drawn  up  in  seven  euro area  Member 
States5. 

Results of the recent Commission services survey indicate that actual migration by PA to the 
SCT schemes remains very slow. In February 2010, the SCT migration rate6 of all euro area 
PA  participating  in  the  survey  stood  at  only  2.5 %  which  is  significantly  below  the  overall 
SCT rate for the euro area (6.2 %) in the same reporting period. Some Member States7 have 
however mentioned specific high-volume PA which will migrate a significant share of their 
transaction  volume  to  SCT  by  end  2010.  Migration  to  SDD  had  practically  not  taken  place 
among  PA  as  of  February  2010.  This needs to be seen in the context of the relatively short 
time  span  elapsed  since  the  launch  of  the  SDD  scheme  (November 2009)  and  the  lesser 
relevance of direct debits as a payment instrument used by PA. 

Migration by European institutions, especially by the Commission (being by far the institution 
with  the  highest  payment  volume),  is  more  advanced.  As  of  June  2010,  almost  all  credit 
transfers  undertaken  by  the  Commission  in  the  SEPA  countries  were  executed  as  SCT  with 
the exception of payments in one Member State8 for which they are expected to fully migrate 
in  September 2010.  The  European  Central  Bank  (ECB)  has  already  fully  migrated  its 
payments  to  SCT  in  January  2008.  The  European  institutions  generally  do  not  use  direct 
debits as payment instruments. 

4 

5 
6 
7 
8 

http://www.europarl.europa.eu/sides/getDoc.do?pubRef=-//EP//TEXT+TA+P7-TA-2010-
0057+0+DOC+XML+V0//EN 
Belgium, France, Italy, Cyprus, Malta, Austria and Slovenia. 
Share of SCT transactions among all credit transfers undertaken. 
Belgium, Germany, France and Portugal. 
Netherlands 

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Table 1: Action items – SEPA migration in public administrations 

Actions 

Actors 

Deadline 

State of play 

Assessment9 

Follow up 

Design national 

Member States 

October 2009 

Completed in 7 

– 

Migration plan in 

migration plans for 

public administrations 

Member States 

only 

Migration of national 

Member States 

End-2010 

SCT: 2.5% 

– 

public administrations 

to SEPA standards, 

products and services 

migration rate 

(February 2010) 

SDD: has 

practically not yet 

taken place 

one additional 

Member State 

expected in 

remainder of 2010 

On the basis of 

Member States 

information, SCT 

rate expected to rise 

significantly by end 

2010 

Migration of 

Commission/ 

June 2010 

Migration to SCT 

+ 

Commission: 

European institutions 

other European 

to SEPA standards, 

Institutions 

products and services 

in Commission 

almost completed 

100 % SCT rate 

for ECB 

payments in one 

remaining Member 

State (NL) to 

migrate in 

September 2010 

2.2. 

Efficient migration monitoring 

Thorough  monitoring  of  the  SEPA  migration  process  is  crucial  in  order  to  anticipate  and 
remedy  potential  problems.  For  this  purpose,  the  ECOFIN  Council  conclusions  of 
22 January 200810 invited the Commission in cooperation with the ECB to provide an Annual 
Progress Report on the state of SEPA migration. The last Progress Report has been published 
in December 200911. The publication of the 2010 Progress Report is expected by end 2010. 

Furthermore, the Eurosystem prepares its own SEPA Progress Reports. Six Progress reports 
have been published to date – the last one in November 200812. A forthcoming 7th Progress 
Report is currently under preparation. 

Actual migration to SEPA instruments is monitored by the ECB and the respective indicators 
are  published  on  the  ECB  website13.  These  include  euro area  SCT  and  SDD  rates  on 
a monthly  basis,  SCT  rates  in  individual  Member  States  on  a  bi-annual  basis,  and  EMV14 
related payment card indicators on a quarterly basis. 

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10 
11 
12

13 
14 

Action completed 
(Some) progress achieved  
Progress not satisfactory 

(cid:57) 
+ 
– 
http://www.consilium.europa.eu/uedocs/cms_data/docs/pressdata/en/ecofin/98276.pdf 
http://ec.europa.eu/internal_market/payments/docs/sepa/progress_report_2009_en.pdf 

http://www.ecb.int/pub/pdf/other/singleeuropaymentsarea200811en.pdf?eaca1262fbf37b7f0fd1

16c37196ce1b 
http://www.ecb.int/paym/sepa/about/indicators/html/index.en.html 
The standard ensuring interoperability between the chips on payment cards and point-of-sale terminals 
or  ATMs.  The  acronym  EMV  represents  the  three  organisations  originally  developing  the  standard  – 
Europay, MasterCard and VISA. 

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To  address  the  particular  importance  of  migration  to  SEPA  by  public  administrations  (PA), 
the Commission services undertake surveys among PA in all Member States. The results of 
these surveys are analysed and published in a scoreboard. Two scoreboards have already been 
published in 200915. The results of the second scoreboard have been updated in the context of 
the 2009 Progress Report, and a new scoreboard is to be published by October 2010. 

One  of  the  most  important  aspects  of  migration  to  SEPA  is  its  impact  on  consumers,  in 
particular  for  the  pricing  of  payment  services.  For  this  purpose,  the  Commission  has 
undertaken  a  first  (pre-SEPA)  benchmarking  study  in  2007  which  will  serve  as  a  basis  for 
comparison with later (post-SEPA) benchmarking studies. The Commission plans to initiate 
the  first  follow-up  study  once  SEPA  instruments  (in  particular  SCT  and  SDD)  are  more 
broadly used. 

Table 2: Action items – Migration monitoring 

Action 

Actors 

Deadline 

State of play 

Assessment 

Follow up 

Annual progress 

Commission in 

Forthcoming: 

Last Progress 

report to ECOFIN 

cooperation 

2010 

Council on state of 

with ECB 

Report published in 

December 2009 

migration 

Eurosystem SEPA 

Eurosystem 

At regular 

Six reports 

Progress Reports 

intervals (last 

published to date 

report November 

2008) 

Publication of SEPA 

ECB 

Throughout the 

SCT, SDD and EMV 

indicators 

migration phase 

indicators published 

on a regular basis 

(cid:57) 

(cid:57) 

(cid:57) 

2010 progress 

report to be 

published by end of 

year 

7th Progress Report 
under preparation 

Ongoing 

Publication of a 

Commission 

From 2009 

Two scoreboards 

(cid:57) 

Next scoreboard to 

biannual scoreboard 

on public 

administrations 

migration 

2nd SEPA 
benchmarking study 

during the 

published on 

migration phase 

Commission 

website 

be published by 

October 2010 

Commission 

Mid-2011 

Critical mass / 

- 

Study postponed 

maturity of SEPA 

instruments required 

for study to be 

meaningful 

due to slow 

migration of SCT 

and SDD 

instruments 

2.3. 

Need to agree on an end-date 

A  public  stakeholder  consultation  on  whether  and  how  deadlines  should  be  set  for  the 
migration  of  existing  national  credit  transfers  and  direct  debits  to  the  new  SEPA  payment 
schemes was organised by the Commission services between June and August 2009 and the 
results published in September 2009 on the Commission services website16. 

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16 

http://ec.europa.eu/internal_market/payments/sepa/ec_en.htm 
http://ec.europa.eu/internal_market/payments/docs/sepa/feedback_migration-2009_09_29_en.pdf 

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Furthermore, discussions and exchanges of opinions were held between September 2009 and 
June 2010 with Member States, financial institutions, consumer organisations and other social 
and economic partners. 

The  ECB,  the  Council  and  the  European  Parliament  have  continued  to  show  their  strong 
support for this initiative. On 2 December 2009, the ECOFIN Council issued conclusions on 
SEPA, stating the following: "The Council (…) CONSIDERS that establishing definitive end-
dates for SDD and SCT migration would provide the clarity and the incentive needed by the 
market, ensuring that the substantial benefits of SEPA are rapidly achieved and that the high 
costs of running both legacy and SEPA products in parallel can be eliminated (…) INVITES 
therefore  the  Commission,  in  collaboration  with  the  ECB  and  in  close  cooperation  with  all 
actors concerned, to carry out a thorough assessment of whether legislation is needed to set 
binding end-dates for SDD and SCT and to come up with a legislative proposal should this 
assessment confirm the need for binding end-dates." 

Similarly,  the  European  Parliament  adopted  on  10  March  2010  a  second  resolution  on  the 
implementation of SEPA calling "on the Commission to set a clear, appropriate and binding 
end-date,  which  should  be  no  later  than  31  December  2012,  for  migrating  to  SEPA 
instruments, after which all payments in euros must be made using the SEPA standards"17 

On 2 June 2010, the Commission services published a working paper18 containing some ideas 
on possible approaches to setting a migration end-date and the way forward. The Commission 
plans to adopt a proposal in this context in early autumn 2010. The Impact Assessment for the 
setting of a migration end-date will be published together with the Commission proposal. 

Table 3: Action items – SEPA migration end-date 

Actions 

Actors 

Deadline 

State of play 

Assessment 

Follow up 

Consultation of 

Commission 

3.8.2009 

See above 

stakeholders based 

on consultation paper 

Political endorsement 

ECOFIN Council 

December 

ECOFIN Conclusions 

2009 

on 2.12.2009 

Completion of impact 

Commission 

February 

Impact Assessment 

assessment work 

2010 

work on track 

(cid:57) 

(cid:57) 

(cid:57) 

Commission 

proposal in early 

autumn 2010 

Commission 

proposal in early 

autumn 2010 

Impact 

Assessment to be 

published together 

with Commission 

proposal 

17 

18 

http://www.europarl.europa.eu/sides/getDoc.do?pubRef=-//EP//TEXT+TA+P7-TA-2010-
0057+0+DOC+XML+V0//EN 
http://ec.europa.eu/internal_market/payments/docs/sepa/end-date_migration_en.pdf 

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3. 

PRIORITY 2: RAISE SEPA AWARENESS AND PROMOTE SEPA PRODUCTS 

For  SEPA  to  be  a  success  it  is  indispensable  to  ensure  that  all  stakeholders  involved  in  the 
'SEPA  changeover'  are  properly  informed.  Major  users,  such  as  corporates  and  public 
administrations,  but  also  consumers,  need  to  be  aware  of  the  opportunities,  benefits  and 
challenges of the SEPA project. Certain categories of users such as public administrations and 
companies  may  need  more  targeted  information  so  as  to  better  understand  and  evaluate  the 
impact of SEPA on their internal processes. 

At national level, the effort to both raise SEPA’s awareness  and  promote SEPA products is 
primarily  a  task  for  Payment  Service  Providers  which  should  design  and  disseminate 
appropriate information on the main characteristics of SEPA products. Nevertheless, given the 
substantial  benefits  to  society,  public  authorities  also  have  an  important  role  to  play  in 
promoting  SEPA.  They  can  do  so  indirectly,  by  leading  by  example  through  the  early 
adoption of SEPA products and directly by either launching their own or (co-)financing public 
information/communication campaigns. 

The level and intensity of current SEPA communication efforts at national level differ from 
one Member States to another. In some Member States, general SEPA awareness is ensured 
by coordinated efforts between the private and public sectors19, while in many others, SEPA 
communication  is  entirely  left  to  the  private  sector20,  sometimes  in  close  cooperation  with 
national central banks21. Communication activities in most non-euro area Member States are 
linked to the (potential) euro accession. 

National SEPA coordination committees have been set up in all Member States to coordinate 
and  monitor  SEPA  implementation  as  well  as  to  identify  the  challenges  in  the  SEPA 
migration  process.  Concerning  the  level  of  involvement  of  end-users  in  national  SEPA 
coordination committees, significant differences between Member States can be observed. In 
most  euro area  Member  States,  end-users  are  present  in  national  SEPA  coordination 
committees22,  while  in  some  cases  national  SEPA  coordination  committees  are  only 
composed  of  the  banking  sector,  in  close  cooperation  with  national  central  banks  or  State 
Treasuries23.  In  Slovenia,  the  participation  in  the  national  SEPA  coordination  committee  is 
entirely  left  to  the  banking  industry.  Outside  the  euro area,  almost  all  national  SEPA 
coordination  committees  are  composed  of  the  banking  sector,  in  close  cooperation  with 
national central banks or Ministries of Finance.  

The Commission has established the EU Forum of national SEPA Coordination Committees 
to  bring  together  the  above  mentioned  national  SEPA  Committees.  This  forum  provides 
a useful  opportunity  for  national  committees  to  familiarize  themselves  with  the  activities  of 
their  European  counterparts,  debate  issues  of  common  interest  with  the  EU  institutions  and 
exchange  information  and  good  practices  about  SEPA  migration.  The  forum  meets 

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21 
22 
23 

Belgium, France and Netherlands. 
Czech Republic, Denmark, Germany, Estonia, Luxembourg, Hungary, Austria, Poland and Finland. 
Italy, Cyprus, Latvia, Lithuania, Portugal, Slovenia and Slovakia. 
Belgium, Greece, Spain, France, Italy, Cyprus, Netherlands, Austria, Portugal, Slovakia and Finland. 
Germany, Luxembourg and Malta. 

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bi-annually  and  information  about  each  of  these  meetings  is  available  on  the  Commission 
services website24. 

At European level, the Commission and the ECB address and will continue to address SEPA 
issues through a variety of channels such as: press releases, public speeches, reports on SEPA 
progress, web-sites, PA surveys25, leaflets26 etc. The European Payments Council (EPC) itself 
has  a  crucial  communication  role  for  SEPA  and  has  already  undertaken  a  number  of 
communication  initiatives.  In  order  to  address  the  different  categories  of  stakeholders,  the 
EPC  has  published  a  series  of  SEPA  brochures  for  consumers,  businesses,  public 
administrations,  merchants,  and  IT  providers27.  The  EPC  has  also  developed  information 
leaflets  for  the  different  SEPA  instruments  (SCT,  SDD,  cards)  and  issues  a  quarterly 
newsletter which is frequently downloaded across all market segments and SEPA countries. 

Table 4: Action items – SEPA awareness and promotion 

Actions 

Actors 

Deadline 

State of play 

Assessment 

Follow up 

Support industry’s efforts 

Member States 

End-2009 

National SEPA 

+ 

Close monitoring of 

to create SEPA 

awareness 

committees 

established in all 

Member States 

End user 

involvement not 

always sufficient 

the improvements 

regarding end user 

representation in 

national committees 

where it is not yet 

sufficiently ensured 

and communication 

activities all Member 

States 

Complement industry 

Commission, 

End-2009 

Large number of 

(cid:57) 

Ongoing 

and national SEPA 

ECB, EPC 

communication with 

initiatives at EU level 

communication 

activities 

undertaken 

Regular meetings of EU 

Commission 

From October 

Meetings take 

(cid:57) 

Ongoing 

forum for SEPA national 

coordination committees 

2008 during 

place bi-

the migration 

phase 

annually. Last 
(4th) meeting on 
5.5.2010 

Active marketing of 

Payment Service 

Immediate 

Need for more 

- 

SEPA products 

appropriate to the 

different user groups: 

concrete SEPA product 

offerings to customers 

Providers (PSP) 

effect for SCT 

proactive 

and 1.11.2009 

communication 

for SDD 

and marketing 

by PSPs 

Next meeting 

planned for 

22.10.2010 

To be addressed in 

context of setting a 

migration end-date 

24 
25 

26 

27 

http://ec.europa.eu/internal_market/payments/sepa/ec_en.htm 
The Commission services intend to prepare a full scoreboard on the migration of PA across the EU for 
publication around the summer. 
Leaflet on SEPA: What it means for consumers and SMEs; 
Leaflet on PSD: What it means for consumers. 
http://www.europeanpaymentscouncil.eu/ 

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4. 

PRIORITY 3: DESIGN A SOUND LEGAL ENVIRONMENT FOR SEPA AND STRENGTHEN 
SEPA COMPLIANCE 

4.1. 

Complete the legal framework for SEPA 

The transposition process of the Payment Services Directive (PSD) which provides the legal 
foundation  of  SEPA  and  had  to  be  implemented  by  1  November  2009  is  almost  achieved. 
However,  there  is  a  small  group  of  Member  States  which  lag  behind.  The  Commission 
launched  a  number  of  infringement  procedures  earlier  this  year.  In  the  context  of  these 
procedures, Greece, Spain, Cyprus, Poland, Romania and Sweden received reasoned opinions 
on 3 June 2010 requesting them to fully implement the PSD in their national laws. Since that 
date, four of the above mentioned Member States (Greece, Spain, Cyprus and Sweden) have 
passed  the  required  national  measures  for  incorporating  the  obligations  of  the  PSD  into 
domestic  law.  In  Romania,  additional  legislation  is  still  required  in  order  to  implement 
a number  of  provisions,  mainly  related  to  the  prudential  requirements  for  payment 
institutions.  In  Poland,  all  PSD  provisions  still  have  to  be  implemented  and  transposition 
should be completed by end October 2010. 

Almost  all  Member  States,  except  Germany  and  the  Czech  Republic,  found  a  solution  to 
ensure the continued legal validity of existing direct debit mandates when migrating to SEPA 
direct  debit,  e.g.  during  the  PSD  transposition.  SDD  migration  should  not  require  the 
re-signature  of  millions  of  new  mandates.  This  would  be  extremely  burdensome  and  costly, 
especially in Member States with high direct debit volumes. 

Table 5: Action items – Legal framework for SEPA 

Actions 

Actors 

Deadline 

State of play 

Assessment 

Follow up 

Ensure complete, 

Member States 

1.11.2009 

25 Member States 

+ 

consistent and faithful 

PSD transposition 

have completed the 

transposition of PSD 

Implementation work 

in Poland and 

Romania still ongoing 

Find a solution ensuring 

Member States 

Solution to be 

25 Member States 

+ 

continued legal validity of 

existing direct debit 

mandates when 

migrating to SEPA direct 

debit 

put in place 

found a solution for 

by 1.11.2009 

the continued legal 

validity of existing 

mandates 

Infringement 

proceedings 

under Article 258 

TFEU ongoing 

Ensure that the 

two remaining 

Member States 

find a solution 

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4.2. 

Competition issues 

In accordance with the SEPA Roadmap, the Commission services published for consultation 
on 3 November 2009, a working document addressing the compatibility of multilateral inter-
bank payments for a possible long-term SDD business model with the EU competition rules28. 
This document complements the provisions of Regulation (EC) No 924/2009 on cross-border 
payments  in  the  Community29  and  the  joint  statement  of  the  Commission  and  the  ECB  of 
24 March 200930.  The  working  document  indicated  that  a per-transaction  multi-lateral 
interchange fee did not seem to be compatible with the EU competition rules and could not 
properly  incentivize  the  efficient  use  of  the  scheme.  However,  the  working  document 
indicated that other arrangements such as a SHARE option or such as a multi-lateral fee for 
error transactions (or 'R-transactions'), if properly designed, could be compatible. Prior to the 
consultation,  on  26  June  2009  the  EPC  plenary  meeting  had  decided  not  to  continue  the 
discussion with the Commission on this topic and in fact there was no industry-wide common 
response to the consultation. 

Although  identified  as  an  action  for  the  EPC  in  the  SEPA  Roadmap  to  be  completed  by 
November 2012, the EPC has decided not to continue work on designing and implementing a 
long-term SDD business model which is compatible with competition rules. 

Table 6: Action items – SDD business model 

Actions 

Actors 

Deadline 

State of play 

Assessment 

Follow up 

Provide further clarity as 

Commission 

November 

Commission 

(cid:57) 

No industry-wide 

to compliance of long-

term business models for 

SDD with EU competition 

law 

2009, provided 

Working 

that necessary 

Document 

contributions 

published on 

from relevant 

3.11.2009 

market actors 

have been 

made 

Design and 

EPC 

1.11.2012 

EPC sees 

– 

implementation of long-

term business models for 

SDD in line with 

competition rules 

responsibility 

for this action 

item with 

scheme 

participants 

contribution on 

working document 

received. To be 

assessed whether 

binding guidance 

needed by 

regulatory means 

To be assessed 

whether binding 

guidance needed 

by regulatory 

means 

28 
29 
30

http://ec.europa.eu/competition/sectors/financial_services/SEPA_working_document.pdf 
http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2009:266:0011:0018:EN:PDF 

http://europa.eu/rapid/pressReleasesAction.do?reference=IP/09/468&format=HTML&aged=0

&language=EN&guiLanguage=en 

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4.3. 

Compliance issues 

The  Eurosystem  has  published  detailed  Terms  of  Reference  (ToR)31  for  card  schemes  and 
infrastructures as well as a set of expectations32 for different stakeholders regarding the SEPA 
project. 

In  terms  of  implementing  the  Eurosystem’s  ToR,  13  card  schemes33  and  16  clearing  and 
settlement  infrastructures34  have  published  SEPA  compliance  self-assessments  on  their 
websites.  On  the  basis  of  an  analysis  of  these  self-assessments,  the  Eurosystem  will  review 
the SEPA compliance criteria and ToR for card schemes and infrastructures. 

The  expectations  for  banks  and  payment  institutions  published  by  the  Eurosystem  were 
intended  to  provide  a  benchmark.  Payment  service  providers  were  invited  to  assess  their 
services against these criteria on a regular basis and to publish the results. The expectations 
for  payment  users  are  meant  to  show  how  migration  to  SEPA  can  be  actively  promoted, 
providing  guidance  for  implementing  SEPA  and  giving  an  impression  of  what  successful 
SEPA implementation would mean for users, as well as how they could benefit from it. The 
Eurosystem has, however, not specifically followed-up on compliance with these expectations 
and has not requested to receive any of the payment user self-assessments. It is therefore not 
possible to evaluate the progress on this action item. 

31 

32 
33 

34 

See http://www.ecb.europa.eu/paym/sepa/components/infrastructures/html/tor.en.html for the Terms of 
reference for the SEPA – compliance of infrastructures and 
http://www.ecb.int/paym/sepa/pdf/ToR_SEPA_compliant_card_schemes.pdf?1915cf8db5ec194b2c9e9
070ebeb2ff7 for Terms of reference for the SEPA compliance of card schemes. 
http://www.ecb.int/pub/pdf/other/eurosystemsepaexpectations200903en.pdf 
Activa (SI), American Express, Bancomat/PagoBancomat (IT), Cartes Bancaires (FR), Euro 6000 (ES), 
Girocard  (DE),  LaserCard  (IE),  MasterCard,  Multibanco  (PT),  PIN  (NL),  Servired  (ES), 
Sistema 4B (ES) and Visa. 
Bankart,  CEC,  Dias,  EKS,  EBA  Clearing,  Eurogiro,  Equens,  Iberpay,  ICBPI/BI-COMP,  KIR,  RPS, 
SIA-SSB/BI-COMP, SIBS, STEP.AT, STET and VocaLink. 

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Table 7: Action items – Compliance 

Actions 

Actors 

Deadline 

State of play 

Assessment 

Follow up 

Implement Eurosystem’s SEPA ToRs for 

1) card schemes  Card schemes 

June 2009 

13 card schemes 

+ 

published self-assessment. 

Other card schemes 

intending to become SEPA 

compliant should conduct 

and publish their self-

assessments. Already 

published self-

assessments should be 

updated if necessary 

Based on the self-
assessments, 
Eurosystem will review 
the SEPA compliance 
criteria and the ToR. 
Changes to the EPC’s 
SEPA Cards Framework 
and other relevant 
developments in the card 
schemes market will be 
taken into account 

2) infrastructures 

Infrastructures 

End-2010 

16 clearing and settlement 

+ 

Based on the self-

infrastructures published 

self-assessment 

assessments, 

Eurosystem will review 

the SEPA compliance 

criteria and the ToR. 

Implications of the SDD 

launch and relevant 

developments in the 

CSM market will be taken 

into account 

5. 

PRIORITY 4: PROMOTE INNOVATION 

An  integrated  payments  market  could  create  significant  opportunities  for  innovation.  In 
particular,  SEPA  could  act  as  a  launching  pad  for  harmonising  payments  through  mobile 
phones (m-payments) or the internet (e-payments). Similarly, SEPA could facilitate the move 
towards electronic invoicing (e-invoicing). 

In  the  area  of  m-payments,  the  EPC  is  working  on  a  series  of  documents  which  aim  at 
creating  a  supportive  framework  for  mobile  contact-less  card  payments  and  remote  mobile 
payments based on cards and SEPA credit transfers. A first White Paper on mobile payments 
has  been  published  by  the  EPC  on  2 July 201035.  This  document  focuses  on  mobile 
contactless card payments. The paper is based on the underlying assumption that "…mobile 
payments  do  not  modify  the  role  of  existing  stakeholders  during  the  actual  card  payment 
transaction".  A  second  edition  of  the  White  Paper  concentrating  on  remote  payments  is 
planned for publication in the third quarter of 2011. Implementation guidelines for both types 
of mobile payments should be produced by the EPC in the 2011–2012 timeframe. 

Regarding e-payments, work at the EPC is still ongoing. As a first deliverable, the EPC plans 
to  publish  a  framework  facilitating  online  payments  with  a  payment-guarantee  for  web 
retailers  through  use  of  the  SEPA  Credit  Transfer  by  online  banking.  The  objective  of  this 
framework  is  to  enable  currently  existing  national  e-payment  schemes  based  on  similar 

35 

http://www.europeanpaymentscouncil.eu/documents/EPC492-
09%20White%20Paper%20Mobile%20Payments%20version%202.0%20finalrev.pdf 

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technical and business models to interlink at SEPA level. In the context of this framework, the 
EPC  intends  only  to  define  minimum  criteria,  including  legal  and  security  aspects,  which 
must be fulfilled by all online banking based e-payment scheme in order to meet the criteria 
of  the  framework.  While  progress  has  been  made  at  technical  level,  the  outstanding  issues 
mainly  concern  the  scope,  legal  form,  and  governance  of  such  a  framework  and  hence  the 
future market structure. 

Both  the  m-  and  e-payments  frameworks  under  development  by  the  EPC  are  limited  to 
describing  specific  technical  and  business  models.  They  will  be  voluntary,  meaning  that 
market players themselves will decide on adherence to a framework. 

As concerns e-invoicing, the independent expert group set up by the Commission at the end of 
2007  has  completed  its  work.  The  final  report  of  the  group  has  been  published  on 
30 November 2009  and  includes  a  proposal  for  a  European  e-Invoicing  framework36.  The 
objective  of  the  framework  is  to  facilitate  the  uptake  of  open  and  interoperable  electronic 
invoicing solutions within the EU. In this context, particular emphasis was put on the needs of 
small  and  medium  enterprises  (SMEs).  The  report  was  subject  to  a  public  consultation, 
a summary of which has been published on the Commission services website37. On the basis 
of  the  final  report  and  the  results  of  the  consultation,  the  Commission  plans  to  adopt 
a Communication on e-invoicing before the end of this year. 

Table 8: Action items – Promoting innovation 

Actions 

Actors 

Deadline 

State of play 

Assessment 

Follow up 

Deliver framework for m-

EPC, GSMA 

August 2010 

First White 

+ 

Second version of 

payments 

(association of 

mobile operators) 

Paper, focussing 

on mobile 

contact-less card 

payments 

published on 

2.7.2010 

White Paper, 

focussing on remote 

payments expected 

in 2011 

Implementation 

guidelines in 2011–

2012 

Deliver framework for e-

EPC 

End-2009 

Work ongoing but 

– 

First deliverable to 

payments 

further delays to 

be expected. 

be finalised 

(framework 

facilitating online 

payments with a 

payment guarantee) 

Complete European 

Expert group on 

End-2009 

Final report of the 

(cid:57) 

Commission to 

framework for e-invoicing 

e-invoicing 

expert group 

published. Public 

consultation 

completed 

adopt a 

Communication on 

e-invoicing based 

on final report and 

consultation 

36 
37 

http://ec.europa.eu/internal_market/consultations/docs/2009/e-invoicing/report_en.pdf 
http://ec.europa.eu/internal_market/payments/docs/einvoicing/summary_report_en.pdf 

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6. 

PRIORITY  5:  ENSURE  NECESSARY  STANDARDISATION,  INTEROPERABILITY  AND 
SECURITY 

Standardisation and interoperability are the technical cornerstones of the SEPA project. It is 
crucial  that  all  SEPA  instruments  allow  for  straight-through  processing  along  the  entire 
payment chain while ensuring a high level of security. 

Adherence  to  the  SDD  scheme  launched  in  November  2009  is  significant  with  more  than 
2 800  banks  (representing  more  than  70 %  of  the  SEPA  payments  volume)  adhering  to  the 
scheme. Adherence is expected to increase close to a 100 % by 1 November 2010 when the 
reachability  obligation  under  Regulation  924/2009  comes  into  force  for  euro area  banks. 
Actual usage of the SDD scheme, however, currently still remains extremely low. 

While the EPC has developed implementation guidelines for the SCT and both SDD schemes 
across  all  domains  (customer-to-bank  and  bank-to-customer),  payment  service  providers 
(PSPs) and users are slow in actively communicating and implementing these guidelines. 

Standardisation  work  on  the  SEPA  cards  framework  (SCF)  by  the  EPC  is  lagging  behind. 
This  has  repercussions  on  the  original  timeline  set  by  the  EPC  and  the  implementation  of 
technical specifications for card standards by the cards industry. The finalisation of the SEPA 
Cards  Standardisation  Volume  and  its  implementation  by  end-2010  does  not  seem  realistic 
anymore, highlighting the need for an acceleration of the current work pace in the cards area. 

Table 9: Action items – Standardisation, interoperability, security 

Actions 

Actors 

Deadline 

State of play 

Assessment 

Follow up 

Establish 

EACT, in 

June 2009 

Standard for 

+ 

Standard should 

consensus on the 

cooperation with 

use of standards for 

users 

structuring the 

unstructured 

remittance 

information (SCT) 

formatting contents 

of unstructured 

remittance 

information 

developed by the 
EACT38. 

be freely 

accessible on 

EACT website 

without need for 

prior registration 

EPC to include 

necessary 

references to the 

standard in the 

upcoming SCT 

rulebook release. 

38 

The  standard  specifies  the  elements  enabling  automated  payments  processing  between  business 
partners. Further information at http://www.corporatesepa.com/eact.html. 

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Active 

PSPs, corporates, 

End-2009 

Latest version of 

– 

communication and 

SMEs, public 

implementation of 

administrations, 

SCT implementation 

consumers, 

guidelines in C2B 
domain39 

vendors 

Active 

PSPs, corporates, 

November 2010 

communication and 

SMEs, public 

implementation of 

administrations, 

Core and B2B SDD 

consumers, 

implementation 

vendors 

guidelines in C2B 

domain 

guidelines published 

by EPC in Oct 
200940. Currently, 
the use of 

ISO20022 message 

standards in the 

C2B domain is very 

limited and business 

customers continue 

to initiate their 

payments using 

legacy formats 

Implementation 
guidelines for Core41 
and B2B42 SDD 
scheme in C2B 

domain published 

by EPC in Oct 2009. 

With SDD take up 

still being very 

limited, the use of 

ISO 20022 message 

standards by 

business customers 

in the C2B domain 

is zero or very low 

On the basis of 

Member States 

information, use of 

ISO20022 

standards by 

public 

administrations is 

expected to rise 

during the course 

of 2010 and 2011 

– 

Usage of ISO 

20022 expected to 

increase after 

1.11.2010, when 

reachability 

obligation under 

Regulation 

924/2009 will 

come into force for 

euro area banks 

Definition of SCT 

EPC 

September 2009  Recommendation 

(cid:57) 

Action completed 

and SDD (Core and 

B2B) 

implementation 

guidelines in B2C 

domain 

on customer 

reporting of SCT 

and SDD published 
on 15.10.200943 

39 

40 

41 

42 

43 

The EPC recommended guidelines (a common set of data for exchange between customers and banks) 
established in 2008 are non-mandatory. However, to avoid market partition, all banks should be capable 
of accepting the recommended EPC standards. If not, corporates will be unable to benefit from SEPA. 
http://www.europeanpaymentscouncil.eu/documents/EPC132-
08%20C2B%20CTIG%20V3.3%20Approved.pdf 
http://www.europeanpaymentscouncil.eu/documents/EPC130-
08%20C2B%20Core%20DDIG%20V3.4%20Approved.pdf 
http://www.europeanpaymentscouncil.eu/documents/EPC130-
08%20C2B%20Core%20DDIG%20V3.4%20Approved.pdf 
http://www.europeanpaymentscouncil.eu/documents/EPC188-
09%20Recommendation%20on%20Customer%20Reporting%20SCT%20and%20SDD.pdf 

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Active 

PSPs, corporates, 

June 2010 

EPC implementation 

– 

guidelines only 

recommended, not 

mandated and 

therefore only used 

to very limited 

extent 

To be further 

addressed in 

context of setting a 

SEPA migration 

end-date 

communication and 

SMEs, public 

implementation of 

administrations, 

SCT and SDD 

consumers, 

implementation 

vendors 

guidelines in B2C 

domain 

Adherence to Core 
SDD scheme44 

PSPs 

1.11.2010 

2 831 banks 

+ 

100% adherence 

representing more 

than 70% of the 

SEPA payments 

volume (adherence 

status as of 

9.7.2010) 

expected for 

euro area banks 

after 1.11.2010, 

when reachability 

obligation under 

Regulation 

924/2009 will 

come into force for 

euro area banks 

Complete SCF 

EPC 

End-2009 

Work on SEPA 

– 

Need to speed up 

Volume enabling 

card schemes to 

define concrete 

technical 

implementation 

specifications for 

cards standards 

cards 

standardisation 

"Volume" still 

ongoing. Version 

4.0 published on 
18.12.200945. 
Risk that definitive 

date defined by 

EPC in SCF by 

which all payment 

cards need to 

become SCF 

compliant (end-

2010) cannot be 

respected by the 

market actors. 

standardisation 

work for all 

domains otherwise 

not all options 

identified in the 
SCF46 equally 
feasible. 

EPC established 

Cards 

Stakeholders 

Group (CSG) 

comprising of 

retailers, vendors, 

processors, card 

schemes and 

PSPs. CSG will 

further drive work 

on 'Volume'. 

44 

45 

46

Deadline is only applicable to euro area Member States. Non-euro area Member States should adhere by 
1 November 2014. 
http://www.europeanpaymentscouncil.eu/documents/EPC020-
08%20SEPA%20Cards%20Standardisation%20Volume%20-
%20Book%20of%20Requirements%20v%204%200%20approved.pdf 

http://www.europeanpaymentscouncil.eu/documents/Cards%20SCF%20006%2009%20v%202

%201.pdf, Section 1.2.1. 

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Implementation of 

Cards industry 

End-2009: 

No decision taken 

– 

Unavailability of 

technical 

specifications for 

cards standards 

decision to be 

since the definition 

taken on 

of implementation 

implementation 

specifications is not 

date 

finalised yet. 

Original objective of 

the EPC to have 

SEPA standards 

fully available by 

end 2010 after 

which the gradual 

implementation 

should take place in 

the market, no 

longer seems 

realistic. 

card standards will 

cause a delay in 

SEPA 

implementation for 

payment cards. 

To be assessed 

whether some 

form of 

intervention 

mandating a 

timeline for 

development and 

implementation of 

detailed card 

standards is 

needed. 

Develop best 

EPC 

End-2009 

Recommended 

+ 

Upgrade of SCF 

practices ensuring a 

high level of security 

for SEPA 
transactions47 

EMV compliance for 

cards, terminals and 

ATMs at levels 

between 70 and 

95 % at EU level. 

Full compliance 

expected at 

end-2010. 

Deliver framework 

EPC 

End-2009 

Decision to develop 

for card transactions 

processing 

framework has been 

taken 

Deliver framework 

EPC 

End-2009 

Decision by EPC 

for priority SCT 

scheme 

not to develop SCT 

priority scheme 

Implementation of 

PSPs 

End-2012 

Decision by EPC 

– 

– 

– 

framework for 

priority SCT 
scheme48 

not to develop SCT 

priority scheme 

and 'Volume' 

planned. 

EPC plans to set 

up a European 

Certification 

Management Body 

in cooperation with 

cards schemes. 

EPC to accelerate 

process to deliver 

framework 

No follow-up 

expected at this 

stage 

No follow-up 

expected at this 

stage 

47 
48 

http://ec.europa.eu/internal_market/payments/docs/sepa/sepa-capgemini_study-final_report_en.pdf 
Implementation of the priority SCT scheme should be optional. 

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7. 

PRIORITY 6: CLARIFY AND IMPROVE THE GOVERNANCE OF SEPA 

To  help  remedy  the  need  for  an  over-arching  SEPA  governance  model  at  EU  level  as 
identified  in  the  SEPA  Roadmap,  the  Commission  jointly  with  the  ECB  established  a  new 
SEPA Council bringing together five high-level representatives from key stakeholders on both 
the demand and supply side, as well as four board members of National Central Banks on a 
rotating basis. The first SEPA Council meeting was held on 7 June 2010 and injected a new 
momentum into the SEPA migration process by adopting a formal declaration stressing strong 
support  for  the  establishment  of  end-date(s)  for  migration  to  SEPA  Credit  Transfers  and 
SEPA Direct Debits by means of legislation at EU level49. 

In the context of SEPA governance, the Commission will closely monitor the implementation 
of its SEPA Roadmap and will publish bi-annual progress reports. This document represents 
the first of these reports. 

The  EPC  has  been  striving  to  improve  the  transparency  of  the  existing  EPC  governance 
model.  The  EPC  scheme  management  internal  rules  stipulate  that  all  stakeholders  may 
introduce  formal  suggestions  for  changes  to  the  schemes.  Although  there  is  a  three-month 
public consultation on proposed changes, the evaluation of the feasibility of the latter remains 
at the discretion of the EPC, as does the final adoption of scheme rules. While in a network 
industry,  it  may  not  be  possible  to  implement  all  and  possibly  conflicting  proposals  by  all 
stakeholders, this highlights the importance of proper governance arrangements with careful 
consideration of user concerns. The Commission services will continue to actively and closely 
monitor the implementation of the present governance improvements in the EPC, in particular 
as regards consideration given to consumer interests, and should deficiencies or weaknesses 
emerge, the Commission will not hesitate to bring forward further proposals within the scope 
of future SEPA implementation reports. 

49 

http://ec.europa.eu/internal_market/payments/docs/sepa/council/end-date_declaration_en.pdf 

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Table 10: Action items – SEPA governance 

Action 

Actors 

Deadline 

State of play 

Assessment 

Follow up 

Establishment of 

effective SEPA 

governance structure at 

EU level 

Commission/ 

End-2009 

SEPA Council 

(cid:57) 

Future meetings of 

ECB 

established. 

First meeting on 

7.6.2010. 

SEPA Council on bi-

annual basis 

Biannual reporting of 

SEPA 

From the date 

First report 

(cid:57) 

Ongoing 

progress in the 

governance 

of the official 

published by 

implementation of the 

structure 

establishment 

Commission 

SEPA Framework for 

action 

of the new 

Services in 

SEPA 

October 2010 

governance 

structure 

Adoption of measures to 

EPC 

Renewed efforts to 

+ 

Commission 

the existing EPC 

governance model: 

1) enhance stakeholder 

End-2009 

participation and 

consultation; 

2) increase transparency; 

3) enlarge membership 

to payment institutions 

End-2009 

November 

2009 

involve 

stakeholders on 

demand side 

EPC plenary 

enlarged to 

payment 

institutions 

services will closely 

monitor 

implementation of 

governance 

improvements and 

bring forward further 

proposals if need be 

Evaluation of SEPA 

Commission/ 

End-2011 

SEPA Council 

n/a at this 

Evaluation to be 

governance structure 

ECB 

established 

stage 

carried out closer to 

the deadline 

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