Opinion of the European Central Bank of 24 September 2024 on the reporting of payments statistics to Sveriges Riksbank (CON/2024/33)
Date: 2024-09-24
Institutions: European Central Bank
Subjects: statistics

EN 

ECB-PUBLIC 

OPINION OF THE EUROPEAN CENTRAL BANK 

of 24 September 2024  

on the reporting of payments statistics to Sveriges Riksbank 

(CON/2024/33) 

Introduction and legal basis 

On 5 July 2024 the European Central Bank (ECB) received a request from Sveriges Riksbank for an opinion 

on  a  draft regulatory code  on the reporting  of  payments statistics to  Sveriges Riksbank  (hereinafter the 

‘draft regulatory code’) accompanied by an explanatory memorandum (hereinafter the ‘memorandum’). 

The ECB’s competence to deliver an opinion is based on Articles 127(4) and 282(5) of the Treaty on the 

Functioning  of  the  European  Union  and  Article 2(1),  third  and  fourth  indents,  of  Council  Decision 

98/415/EC1, as the draft regulatory code relates to Sveriges Riksbank and the collection, compilation and 

distribution  of  monetary,  financial,  banking,  payment  systems  and  balance  of  payments  statistics.  In 

accordance with Article 17.5, first sentence, of the Rules of Procedure of the European Central Bank, the 

Governing Council has adopted this opinion. 

1. 

Purpose of the draft regulatory code 

1.1  Background 

As noted in the memorandum, according to the Law on Sveriges Riksbank 2, Sveriges Riksbank must 

monitor  developments  in  the  payments  market  and  contribute  to  the  public  being  able  to  make 

payments.  Sveriges  Riksbank  must  also  ensure  that  the  public  is  able  to  make  payments  during 

peacetime crisis situations and in the event of elevated preparedness, and keep inflation permanently 

low and stable. A prerequisite for Sveriges Riksbank to be able to meet its obligations is the possibility 

to collect and analyse statistics in the area of payments 3.  

According  to  the  memorandum,  there  are  currently  no  comprehensive  statistics  on  the  Swedish 

payments  market.  Sveriges  Riksbank  does  not  have  access  to  basic  information  on  the  Swedish 

payments market, such as the total volume of transactions, their value and how they are distributed 

between different payment service providers. In addition, Sweden is one of the few Member States 

that do not collect statistics corresponding to the data required to be reported under Regulation (EU) 

No  1409/2013  on  payments  statistics  (ECB/2013/43) 4  (hereinafter  the  ‘ECB  Payments  Statistics 

1  

2  
3 
4  

Council Decision 98/415/EC of 29 June 1998 on the consultation of the European Central Bank by national authorities 
regarding draft legislative provisions (OJ L 189, 3.7.1998, p. 42). 

Lag (2022:1568) om Sveriges riksbank. 
See p. 1 and Section 1.1 of the memorandum. 

Regulation  (EU)  No  1409/2013  of  the  European  Central  Bank  of  28  November  2013  on  payments  statistics 
(ECB/2013/43) (OJ L 352, 24.12.2013, p. 18). 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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Regulation’), so there is also a lack of comparable statistics between Sweden and the other Member 

States 5.  

Against  this  background,  Sveriges  Riksbank  proposes  new  rules  on  the  reporting  of  payments 

statistics.  As  noted  in  the  memorandum,  the  draft  regulatory  code  aims  to  improve  Sveriges 

Riksbank’s  analytical  basis  and  enable  it  to  continuously  monitor  developments  on  the  payments 

market  based  on  the  data  collected.  The  draft  regulatory  code  also  aims  to  improve  Sveriges 

Riksbank’s analytical basis for its monetary policy work, as the data are important for analysis of the 

current  situation  and  short-term  forecasts  for  the  Swedish  economy.  The  data  are  particularly 

important  for  analysing  developments  in  household  consumption  and  for  providing  Sveriges 

Riksbank with better information on the sectors to which payments are made6. 

1.2  Scope of application 

The  draft  regulatory  code  applies  to  payment  service  providers  and  payment  system  operators 

resident in Sweden and to foreign payment service providers with a branch in Sweden (hereinafter 

‘reporting  agents’).  For  a  reporting  agent  operating  abroad,  only  activities  that  take  place  directly 

across national borders are covered, and not activities carried out through branches or subsidiaries 

abroad.  Moreover,  the  draft  regulatory  code  will  not  apply  to  payment  service  providers  that  only 

provide account information services7. 

1.3  Reporting requirements 

According to the draft regulatory code, payment service providers are to provide information on a 

number of items, including card-based payment transactions, credit transfers, direct debits, e-money 

payment transactions, automatic teller machine (ATM) and over-the-counter (OTC) cash deposits, 

and ATM and OTC cash withdrawals. Of the items listed, the majority need to be reported for each 

individual payment transaction (hereinafter the ‘individual items’), while the rest need to be reported 

at an aggregate level (the ‘aggregated items’) 8. 

Payment  service  operators  are  to  provide  information  on  a  number  of  items,  including  direct  and 

indirect  participants,  card-based  payment  transactions,  credit  transfers,  direct  debits,  e-money 

payment transactions, ATM and OTC cash deposits, and ATM and OTC cash withdrawals. All of the 

items listed must be reported at an aggregate level 9. 

1.4  Frequency of reporting  

Payment  service  providers  must  report  individual  items  every  calendar  week  and  the  aggregated 

items  every  calendar  quarter10.  However,  if  the  payment  service  provider  is  part  of  the  group  of 

payment  service  providers  whose  total  number  or  value  per  payment  service  in  respect  of  the 

individual items is more than 5 % but no more than 15 % of the total number or value per calendar 

year  for  all  payment  service  providers,  Sveriges  Riksbank  may  decide  that  ‒  in  respect  of  the 

individual items ‒ the payment service provider is to report every calendar quarter instead of every 

5 
6 
7 
8  
9  
10  

See p. 1 of the memorandum. 
See pp. 1-2 and Section 1.2 of the memorandum. 

See Section 1 of the draft regulatory code. 
See Section 3 of the draft regulatory code. 
See Section 7 of the draft regulatory code. 

See Section 4 of the draft regulatory code. 

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calendar  week.  If  the  payment  service  provider  is  part  of  the  group  of  payment  service  providers 

whose total number or value per payment service in respect of the individual items is not more than 

5  %  of  the  total  number  or  value  per  calendar  year  for  all  payment  service  providers,  Sveriges 

Riksbank may decide that the payment service provider is to report every calendar year instead of 

every calendar week. Reporting in respect of the aggregated items must then be submitted broken 

down by calendar quarter. Sveriges Riksbank may revoke a derogation decision11. 

Payment service operators must report every calendar quarter 12. 

1.5  Correction and verification of reported information  

According to the draft regulatory code, if Sveriges Riksbank discovers that incorrect or incomplete 

information has been submitted, a reporting agent must, at the request of Sveriges Riksbank, submit 

corrections for  up to two years back from  the  date of the report.  A reporting agent that  discovers 

significant errors in previously submitted data must contact Sveriges Riksbank to assess whether 

corrections  should  be  made.  Significant  errors  are  those  which  affect  the  interpretation  of  the 

statistics, and in the case of doubt as to whether or not an error is significant, Sveriges Riksbank 

should be consulted13. In addition, at Sveriges Riksbank’s request, a reporting agent must promptly 

verify  and  explain  any  major  changes  and  deviating  values  in  the  report 14.  According  to  the 

memorandum, the response time may vary depending on whether the report is time-critical in the 

context of Sveriges Riksbank’s analysis of the data or the publication and delivery of the statistics. 

This means that the response time may vary from a few days to a number of weeks, or longer 15. 

1.6  Exemptions from the draft regulatory code 

According  to  the  draft  regulatory  code,  Sveriges  Riksbank  may  allow  exemptions  from  the  draft 

regulatory code in exceptional circumstances 16. The memorandum specifies that Sveriges Riksbank 

may grant exemptions from the draft regulatory code in its entirety if there are special reasons for 

doing  so.  However,  the  possibility  of  granting  exemptions  for  special  reasons  should  be  applied 

restrictively. An example of special reasons is where a reporting agent is prevented in a practical 

sense from reporting on an occasion, for example, because of a fire or similar situation. The size of 

the reporting agent, or the number or value of the transactions do not constitute grounds for deciding 

on exemptions from the code in its entirety 17.  

2. 

General observations 

2.1  Since Sweden is a Member State with a derogation, i.e. that has not adopted the euro as its currency, 

the  ECB  Payments  Statistics  Regulation  does  not  apply  in  Sweden.  In  this  respect,  while  it  is 

recognised18 that regulations adopted by the ECB under Article 34.1 of the Statute of the European 

11  
12  
13  
14  
15  
16  
17  
18  

See Section 5 of the draft regulatory code. 
See Section 8 of the draft regulatory code. 

See Section 10 of the draft regulatory code and Section 2.5 of the memorandum. 
See Section 11 of the draft regulatory code. 

See Section 2.5 of the memorandum. 
See Section 14 of the draft regulatory code. 

See Section 2.7 of the memorandum. 
ECB Payments Statistics Regulation, recital 6.  

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System of Central Banks and of the European Central Bank (hereinafter the ‘Statute of the ESCB’) 

do not confer any rights or impose any obligations on Member States whose currency is not the euro 

(hereinafter the ‘non-euro area Member States’), Article 5 of the Statute of the ESCB on the collection 

of statistical information applies to both Member States whose currency is the euro (hereinafter the 

‘euro  area  Member  States’)  and  non-euro  area  Member  States.  Recital  17  of  Council  Regulation 

(EC) No 2533/98 19 refers to the fact that Article 5 of the Statute of the ESCB, together with Article 

4(3) of the Treaty on European Union 20, implies an obligation to design and implement at national 

level all the measures that the non-euro area Member States consider appropriate in order to carry 

out  the  collection  of  the  statistical  information  needed  to  fulfil  the  ECB’s  statistical  reporting 

requirements and timely preparations in the field of statistics in order for them to become euro area 

Member States.  

2.2  Consistent  with  the  foregoing,  Recommendation  ECB/2013/44  of  the  European  Central  Bank21, 

which is addressed to the national central banks (NCBs) of non-euro area Member States which are 

participating in the framework for collection of payments statistics within the ESCB established under 

the  ECB  Payments  Statistics  Regulation,  provides  that  such  NCBs  should  apply  the  provisions 

addressed  to  the  NCBs  of  euro  area  Member  States  contained  in  the  ECB  Payments  Statistics 

Regulation. As clarified in Recommendation ECB/2013/44, the data collected  from payment service 

providers,  electronic  money  issuers  and  payment  system  operators  under  the  ECB  Payments 

Statistics  Regulation  are  essential  for  identifying  and  monitoring  developments  in  the  payments 

markets  within  the  Member  States  and  for  assisting  in  the  promotion  of  the  smooth  operation  of 

payment  systems 22.  The  NCBs  of  non-euro  area  Member  States  which  are  participating  in  the 

framework for collection of payments statistics should cooperate with each other, with NCBs of euro 

area  Member  States  and  with  the  ECB  in  applying  the  framework  in  accordance  with  the  ECB 

Payments Statistics Regulation 23.  

2.3  The ECB Payments Statistics Regulation provides the following: (i) the NCBs of euro area Member 

States must define and implement the reporting arrangements to be followed by the actual reporting 

population  in  accordance  with  national  characteristics,  as  well  as  ensure  that  these  reporting 

arrangements provide the statistical information required under the Regulation and allow accurate 

checking  of  compliance  with  the  minimum  standards  for  transmission,  accuracy,  compliance  with 

concepts and revisions specified in Annex IV; (ii) for the purposes of granting derogations to reporting 

agents, such NCBs are to be guided by the principle of proportionality; (iii) such NCBs must verify 

compliance with the conditions for granting derogations on an annual basis and in good time in order 

to grant or withdraw any derogation with effect from the start of the second successive calendar year 

where necessary, and that verification must be based on the relevant reporting periods for the 12 

months immediately preceding the reference period in which the assessment is conducted; (iv) such 

19  

20  

21  

22  
23  

Council Regulation (EC) No 2533/98 of 23 November 1998 concerning the collection of statistical information by the 
European Central Bank (OJ L 318, 27.11.1998, p. 8). 

Article 4(3) of the Treaty on European Union provides that pursuant to the principle of sincere cooperation, the Union 
and the Member States shall, in full mutual respect, assist each other in carrying out tasks which flow from the Treaties. 

Recommendation ECB/2013/44 of the European Central Bank of 28 November 2013 on payments statistics (2014/C 
5/01) (OJ C 5, 9.1.2014, p. 1). 
Recital 1 of the ECB Recommendation. 

Recital 2 of the ECB Recommendation. 

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NCBs  must  establish  clear  reporting  deadlines  for  reporting  agents  which  clearly  determine  the 

frequency with which reporting agents are to report to NCBs and ensure that NCBs are able to meet 

their reporting deadlines with the ECB set out in the ECB Payments Statistics Regulation; and (v) 

such NCBs must exercise the right to verify or to collect compulsorily the information which reporting 

agents are required to provide pursuant to the ECB Payments Statistics Regulation, without prejudice 

to the ECB’s right to exercise this right itself and, in particular, such NCBs must exercise this right 

when a reporting agent does not fulfil the minimum standards for transmission, accuracy, compliance 

with concepts and revisions specified in Annex IV of that Regulation24. 

2.4  Sveriges  Riksbank  already  provides  payments  statistics  to  the  ECB  on  the  basis  of  the  Law  on 

Sveriges Riksbank 25 and understands that Sveriges Riksbank will continue to do so going forward in 

accordance with the increased scope of payments statistics collected under the draft regulatory code. 

Against this backdrop, the ECB strongly welcomes the draft regulatory code as it will, in practice, 

facilitate  Sveriges  Riksbank’s  ability  to  follow  Recommendation  ECB/2013/44.  In  addition,  while 

statistics  on  fraudulent  payment  transactions  are  collected  by  the  Swedish  Financial  Supervisory 

Authority  in accordance with the relevant  European Banking  Authority (EBA) guidelines, the  ECB 

takes note that Sveriges Riksbank will aim to support a ‘single data flow’ ‒ aligning with the ECB’s 

statistical reporting requirements in terms of scope and frequency ‒ and report payments statistics 

and statistics on fraudulent payment transactions to the ECB, which could, in turn, share the latter 

with the EBA, provided that the necessary cooperation arrangements are established26.  

2.5  Further,  the  ECB  welcomes  that  the  draft  regulatory  code  will  also  facilitate  Sveriges  Riksbank’s 

ability  to  meet  its  obligations  under  the  Law  on  Sveriges  Riksbank.  The  possibility  to  collect  and 

analyse statistics in the area of payments will enable it to fulfil its mandate, including to contribute to 

the public being able to make payments, to monitor developments in the payments market, to ensure 

that  the  public  is  able  to  make  payments  during  peacetime  crisis  situations  and  in  the  event  of 

elevated preparedness, and to keep inflation permanently low and stable. 

3. 

Specific observations 

3.1  The scope of application of the draft regulatory code is broader and contains more granular details 

compared with the ECB Payments Statistics Regulation. In general, the ECB recommends that the 

draft regulatory code is aligned to the extent possible with the ECB Payments Statistics Regulation. 

This is particularly important to ensure the harmonisation of data sharing and the comparability of 

data  across  EU  Member  States.  In  this  regard,  the  ECB  recommends  that  the  following  areas  in 

particular are aligned as closely as possible to the corresponding provisions of the Regulation.  

3.2  First, the ECB would in principle welcome the inclusion in the reporting population of the same types 

of  payment  service  providers  as  under  the  ECB  Payments  Statistics  Regulation27,  as  the  draft 

regulatory code does not apply to payment service providers that only provide account information 

24  
25  
26  
27  

See Article 3(2), Article 4(1) and (5), Article 6(2) and Article 7 of the ECB Payments Statistics Regulation. 
See Chapter 1, Section 11 of the Law on Sveriges Riksbank. 

See Section 1.6 of the memorandum. 

See Article 2 of the ECB Payments Statistics Regulation. 

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services (AISPs). Unless the information is collected elsewhere, AISPs should be included to report 

data on the number of their clients and the number of accounts accessed by AISPs.  

3.3  Furthermore, the ECB would welcome an update to the provisions of the draft regulatory code on 

corrections  for  incorrect  or  incomplete  previously  submitted  data  to  align  them  with  the  ECB 

Payments Statistics Regulation. The Regulation does not limit the period during which corrections 

can be required from the reporting population. 

3.4  The  proposal  in  the  draft  regulatory  code  for  certain  reporting  agents  to  be  able  to  benefit  from 

derogations  and  report  data  with  a  lower  frequency  suggests  that  a  greater  number  of  reporting 

agents  could  be  granted  derogations  than  is  provided  for  under  the  ECB  Payments  Statistics 

Regulation. This may lead to a scenario where Sveriges Riksbank increasingly reports estimates to 

the ECB rather than normal data, which could compromise Swedish national aggregates and result 

in lesser comparability with other Member States. The ECB therefore recommends that, for weekly 

and quarterly data, the derogations under the draft regulatory code are aligned as much as possible 

with the derogations provided in Article 4 of the ECB Payments Statistics Regulation. Furthermore, 

whenever reporting agents have been granted a derogation, the ECB recommends that grossing-up 

procedures are implemented with the aim of ensuring that the payments statistics reported to the 

ECB are representative of the entire reporting population. 

This opinion will be published on EUR-Lex. 

Done at Frankfurt am Main, 24 September 2024. 

[signed] 

The President of the ECB 

Christine LAGARDE 

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