Opinion of the European Central Bank of 19 August 2025 on the portability of IBAN numbers for bank accounts (CON/2025/24)
Date: 2025-08-19
Institutions: European Central Bank
Subjects: money

ECB-PUBLIC 

EN 

OPINION OF THE EUROPEAN CENTRAL BANK 

of 19 august 2025 

on the portability of IBAN numbers for bank accounts 

(CON/2025/24) 

Introduction and legal basis 

On  25  June  2025  the  European  Central  Bank  (ECB)  received  a  request  from  the  Chairman  of  the 

Committee  on  the  Economy,  Consumer  Protection  and  Digitalisation  of  the  Belgian  Chamber  of 

Representatives for an opinion on a draft law amending the Belgian Code of Economic Law to introduce a 

system for the portability of IBAN numbers for bank accounts (hereinafter the ‘draft law’). 

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), second indent, of Council Decision 98/415/EC 1, as the 

draft  law  relates  to  means  of  payment.  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 law 

1.1  By way of background, Directive 2014/92/EU of the European Parliament and of the Council 

(hereinafter the ‘Payment Accounts Directive’)2, which includes, inter alia, rules on the switching of 

payment accounts, has been transposed into Belgian law3. The account switching service allows 

consumers to switch from one payment service provider (PSP) to another in the same Member 

State at no direct cost. 

1.2  According to the explanatory memorandum accompanying the draft law, Belgian consumers are 

fairly conservative when it comes to changing banks. This conservatism can largely be explained 

by the administrative obstacles involved in switching banks. To ensure optimal competition, it is 

essential that payment service users (PSUs) are able to choose, and therefore also change, their 

PSP easily, quickly and free of charge, according to their needs. The draft law aims at facilitating 

account switching. 

1.3 

In  particular,  the  draft  law  (1)  extends  the  account  switching  rules  currently  only  applicable  to 

payment  accounts  to  regulated  savings  accounts,  (2)  introduces  the  principle  of  account  number 

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2  

3  

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, ELI: http://data.europa.eu/eli/dec/1998/415/oj). 
Directive 2014/92/EU  of  the  European  Parliament  and of the  Council  of  23  July  2014 on the  comparability of  fees 
related to payment accounts, payment account switching and access to payment accounts with basic features (OJ L 
257, 28.8.2014, p. 214, ELI: http://data.europa.eu/eli/dir/2014/92/oj). 
This  transposition  was  achieved  by  amending  Book  VII  of  the  Belgian  Code  of  Economic  Law,  which  deals  with 
payment and credit services. See Code de droit économique du 28 février 2013/Wetboek van economisch recht van 
28 februari 2013, tel que modifié/zoals nader gewijzigd, Moniteur belge/Belgisch Staatsblad, 29.03.2013, p. 19975. 

 
 
 
 
 
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portability  (via  the  IBAN  identifier)  and  (3)  provides  that  the  complete  transaction  history  of  the 

relevant account for the last 10 years must be transferred to the receiving PSP.  

1.4  The  explanatory  memorandum  justifies  the  account  number  portability,  stating  that  it  enables 

consumers who keep their account number to avoid having to inform their creditors and debtors of 

the existence of a new account number.  

1.5  The draft law provides that PSPs must offer the facility of portability of IBAN numbers and provides 

that the King is required to set out by decree adopted by the Council of Ministers (1) the arrangements 

for the portability of IBAN numbers for payment accounts, including the allocation of tasks between 

the parties involved in the transfer, (2) the obligations of PSPs regarding the provision of information 

to  consumers  on  the  portability  of  IBAN  numbers  of  payment  accounts,  (3)  the  methodology  for 

determining  the  costs  of  implementing  this  facility  and  the  allocation  of  these  costs  between  the 

parties  concerned;  the  methods  and  rules  for  allocating  costs  may  not  result  in  any  charges  to 

consumers for the portability of IBAN numbers of payment accounts that would distort competition 

or  discourage  switching,  and  no  direct  charges  are  to  be  levied  on  consumers;  and  (4)  the 

compensation to be paid to consumers in the event of delays in the execution of the transfer.  

2. 

General observations 

2.1 

IBAN 

2.1.1  The  International  Bank  Account  Number  (IBAN)  was  introduced  as  a  mandatory  requirement  for 

equal charging under Regulation (EC) No 2560/2001 of the European Parliament and of the Council4. 

The IBAN has proven to be a cornerstone for the standardisation of payments in the context of the 

Single Euro Payments Area (SEPA) as it enhances straight through processing and facilitates the 

verification of account numbers5.  

2.1.2  The IBAN as defined in Regulation (EU) No 260/2012 of the European Parliament and of the Council6 

(hereinafter  the  ‘SEPA  Regulation’)  is  an  international  payment  account  number  identifier,  which 

unambiguously identifies an individual payment account in a Member State, the elements of which 

are  specified  by  the  International  Organisation  for  Standardisation  (ISO).  In  accordance  with  the 

standards adopted by ISO 7, the IBAN includes alphanumeric characters that identify in which country 

and with  which PSP  the  account is located. Through its ledger,  the  PSP can identify the  account 

holder.  

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5  

6  

7  

Regulation (EC) No 2560/2001 of the European Parliament and of the Council of 19 December 2001 on cross-border 
payments in euro (OJ L 344, 28.12.2001, p.13, ELI: http://data.europa.eu/eli/reg/2001/2560/oj); no longer in force. 
See  paragraph  2.2  of  Opinion  CON/2009/1  of  the  European  Central  Bank  of  6  January  2009  on  a  proposal  for  a 
Regulation of the  European  Parliament and  of the  Council  on  cross-border payments  in the  Community  (OJ  C 21, 
28.1.2009, p. 1).  
Regulation (EU) No 260/2012 of the European Parliament and of the Council of 14 March 2012 establishing technical 
and business requirements for credit transfers and direct debits in euro and amending Regulation (EC) No 924/2009 
(OJ L 94, 30.3.2012, p. 22, ELI: http://data.europa.eu/eli/reg/2012/260/oj); see Article 2, point (15). 
ISO 13616-1 :2020, available on the ISO website at www.iso.org. 

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2.1.3  At least two Union legal acts, namely the SEPA Regulation8 and Regulation (EU) 2021/1230 of the 
European Parliament and of the Council9, refer to the IBAN as an account identifier, requiring PSPs 

to (1) use the IBAN when carrying out credit transfer and direct debit transactions, (2) ensure that 

PSUs use the IBAN for identification of payment accounts and (3) offer payers the service of ensuring 

verification of the payee by comparing the IBAN and the name of the payee. The ECB understands 

that  the  IBAN  is  also  used  for  payment  activities,  such  as  the  routing  or  reporting  of  payments, 
balance of payments, or AML/CFT screening, and also for reporting purposes to support the fight 
against VAT fraud10. 

2.2  Portability of IBAN 

2.2.1  The issue of account number portability has been the subject of numerous studies and discussions 

in recent years at Union level11 and in some Member States12. 

2.2.2  The study which gave rise to the Commission’s April 2021 Report assessed different types of options 

for implementing a Union-wide account number portability but concluded that none of these options 

would be viable from an efficiency standpoint. Although the tools for account number portability would 

greatly  facilitate  switching  in  the  Union,  they  come  with  high  implementation  and  running  costs 

compared  to  their  expected  benefits 13.  In  the  Commission’s  second  May  2023  Report,  the 

Commission,  after  having  described  the  different  options  available  to  organise  payment  account 

number  portability,  states  that  sectoral  organisations  do  not  see  account  number  portability  as  a 

major game-changer for account switching and that consumer organisations have mixed views. The 

report concludes on this point that, while it is clear that possible additional measures could make it 

even easier to switch payment accounts within the Union, based on estimated switching rates and 

8  

9  

10  

11  

12  

13  

See in particular (1) Article 5(1), point (a) of the SEPA Regulation (in conjunction with point (1)(a) of the Annex); (2) 
Article 5(1), point (c) of the SEPA Regulation (in conjunction with point (1)(a) of the Annex); and (3) Article 5c of the 
SEPA Regulation (in conjunction with point (1)(a) of the Annex). 
Regulation (EU) 2021/1230 of the European Parliament and of the Council of 14 July 2021 on cross-border payments 
in the Union  (OJ L 274, 30.7.2021, p. 20, ELI: http://data.europa.eu/eli/reg/2021/1230/oj); see Article 6. 
European Commission: Directorate-General for Financial Stability, Financial Services and Capital Markets Union and 
Deloitte,  Study  on  tools  designed  to  facilitate  switching  and  cross-border  opening  of  payment  accounts  on  the  EU 
payment  accounts  market  –  Final  report,  Publications  Office,  2021,  https://data.europa.eu/doi/10.2874/906198 
(hereinafter the ‘Commission’s April 2021 Report’); see page 42. 
See  (1)  European  Commission:  Directorate-General  for  Financial  Stability,  Financial  Services  and  Capital  Markets 
Union (European Commission), Grimaldi, ICF, Andruszkiewicz, O., Herrera, F. et al., Study on switching of financial 
services and products – Final report, Publications Office, 2019, https://data.europa.eu/doi/10.2874/090150 (hereinafter 
the  ‘Commission’s  November  2019  Report);  (2)  European  Commission:  Directorate-General  for  Financial  Stability, 
Financial  Services  and  Capital Markets  Union  and  Deloitte,  Study on  EU payment  accounts market – Final  report, 
Publications  Office,  2021,  https://data.europa.eu/doi/10.2874/45634  (hereinafter  the  ‘Commission’s  April  2020 
Report’); (3) the Commission’s April 2021 Report; (4) Answer given by Ms McGuinness on behalf of the European 
Commission to Parliamentary question – E-003259/2022(ASW), https://www.europarl.europa.eu/doceo/document/E-
9-2022-003259-ASW_EN.html; (5) Report from the Commission assembling specific payment account related data 
from  Member  States  as  required  by  Article  27  of  the  Directive  2014/92/EU  of  the  European  Parliament  and of  the 
Council on the comparability of fees related to payment accounts, payment account switching and access to payment 
accounts with basic features, COM(2023) 248 final, https://op.europa.eu/en/publication-detail/-/publication/9b630c98-
f0c0-11ed-a05c-01aa75ed71a1/language-en (hereinafter the ‘Commission’s first May 2023 Report’); and (6) Report 
from the Commission to the European Parliament and the Council on the application of Directive 2014/92/EU of the 
European Parliament and of the Council on the comparability of fees related to payment accounts, payment account 
switching and access to payment accounts with basic features, COM(2023) 249 final, https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=COM:2023:249:FIN (the ‘Commission’s second May 2023 Report’). 
See  for  instance  the  numerous  references  to  the  discussions  that  took  place  in  the  Netherlands  included  in  the 
Commission’s November 2019 Report. 

Conclusions of the Executive Summary of the Commission’s April 2021 Report. 

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given  that  the  expected  costs  (including  both  one-off  costs  and  recurring  costs)  would  largely 

outweigh their expected benefits, such measures did not seem justifiable at that stage14. 

2.2.3  The IBAN as it stands today is not portable since in the current legal and technical framework the 

IBAN identifies the PSP holding the payment account.  

2.2.4  Introducing account number portability based on the IBAN may be complex, as it requires technical 

and  operational  changes  to  infrastructure  across  the  whole  chain  of  payments  and  entails  large 

investments in time and money by banks to change their infrastructure. 

2.2.5  While introducing account number portability on a national level is technically possible, though rather 

complex,  it  would  most  probably  be  too  costly  and  economically  not  feasible  if  only  a  small 

percentage of PSUs is inclined to switch bank accounts. Although the Payment Accounts Directive 

lays down rules on switching accounts domestically, by obliging PSPs to facilitate account switching 

at customers’ requests15, there is a still low mobility of PSPs’ customers in the Union. Despite the 

fact that these rules make switching easier for consumers, the percentage of consumers not satisfied 

with their PSPs is still much higher than the percentage of consumers who have considered switching 

accounts.  The  Commission’s  April  2021  Report16  estimates  that  only  0.7%  of  the  Union  banked 

population  over  15  years  old  is  using  the  domestic  switching  service  provided  by  the  Payment 

Accounts  Directive.  Room  for  improvement  therefore  seems  to  exist  when  comparing  account 

switching with switching services in other sectors. In the telecommunications sector, for example, the 

Eurobarometer on E-communications 17 in the Union estimated in 2021 that around 60 % of European 

consumers have changed telecommunications service providers at least once. The portability of a 

phone number is a key element in this process. 

2.2.6  As  mentioned,  the  Commission’s  second  May  2023  Report  concludes  that  the  expected  costs  of 

switching accounts would largely outweigh the expected benefits. While this conclusion is recent, in 

the future it could be challenged by trends like the growth of neobanks offering online services across 

Member States without physical branches, the growing percentage of Union citizens moving to live 

in  another  Member  State,  and  developments  in  information  technology.  These  elements  could 

increase demand for switching services, making them more economically sustainable. In a time when 

digitalisation makes services faster and even instant, it may become difficult for consumers to accept 

that  they  must  wait  for  days  to  transfer  payment  services  from  one  account  to  another.  Should 

initiatives  be  taken  in  that  direction,  it  is  essential  that  they  facilitate  faster,  easier  and  efficient 

account switches on a Union-wide basis, both within and across Member States. 

3. 

Specific observations 

3.1  The draft law merely lays down the principle of IBAN portability, and provides that the arrangements 
for the portability, including the allocation of tasks between the parties involved in the transfer, the 

14  
15  

16  
17  

See paragraph 5.3 of the Commission’s Second May 2023 Report, page 14. 
Chapter III of the Payment Accounts Directive. 
The Commission’s April 2021 Report, page 13.  
See the Special Eurobarometer Report on E-Communications in the Single Market, June 2021, page 27.The proportion 
of those who have never changed provider has decreased by 9 percentage points from April 2017 to November 2020, 
https://europa.eu/eurobarometer/surveys/detail/2232.  

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obligations  of  PSPs  regarding  the  provision  of  information  to  consumers,  the  methodology  for 

determining  the  costs  of  implementing  this  facility  and  the  allocation  of  these  costs  between  the 

parties  concerned  and  the  compensation  to  be  paid  to  consumers  in  the  event  of  delays  in  the 

execution of the transfer, are to be determined by a royal decree adopted by the Council of Ministers. 

The ECB should be consulted on any royal decree implementing the draft law. 

3.2  The national portability solution retained should remain consistent with the Union legal framework. 

In  particular,  considering  the  articulation  between  Union  law  and  the  ISO  standards  defining  the 

current format of the IBAN, the portable payment account number should continue to be compliant 

with the format defined in accordance with the ISO standards in order to be recognized as an IBAN. 

This opinion will be published on EUR-Lex. 

Done at Frankfurt am Main, 19 August 2025. 

[signed] 

The President of the ECB 

Christine LAGARDE 

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