The European Digital Payments Industry Alliance welcomes the European Commission’s October 2022 instant payments proposal. Instant payments offer a range of benefits to consumers and merchants.
To ensure that this proposal positively contributes to the uptake of instant credit transfers, EDPIA believes that co-legislators should consider the following aspects during the legislative process:
- All kinds of payments firms should be incentivized to participate. In this regard, one way forward would be to amend the settlement finality directive (SFD) to ensure all institutions have equal access to infrastructure.
- Price harmonization between corresponding regular and instant credit transfers should appropriately recognize the different solutions and use-cases available. This would further incentivize companies to bring forth new solutions and would create a thriving ecosystem around instant payments
- Technological neutrality is an important principal, especially when developing new tools to tackle financial crime. As such, firms should be incentivized to develop alternative solutions that may be an efficient alternative to IBAN-matching.
- Adapting the sanctions regime to the instant world brings forth new challenges and risks. The EU should introduce a clear timeline to monitor and assess the proposed regime, so as to adjust the negative consequences in the medium-term.
More detail can be found in the paper linked here.