Response to consultation on draft implementing technical standards for uniform reporting under the Single Euro Payments Area Regulation
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1. Do you perceive that the reporting requirements adequately cater for the situation where the PSP has already reported the same data to the authorities?
Some of the stats we reporting in ECB Pay Stats.
3. Do you consider the reporting requirements proposed in templates S 03.00 to be suitable for carrying out a robust analysis and to strike an appropriate balance with the competing need to avoid excessive reporting burden for the industry?
Depending from the answer to the question: How we define reporting country ? If the answer is that we need submit to 26 countries separately, then it is quite big burden for the small company to report.
6. Are the instructions and templates in Annex I and II clear to you or do any of the terms therein require to be defined further?
Some of them are not really clear we have following questions:
- How we define reporting country (would that be Ireland only due to the Irish IBAN MPL provides or Country of Merchant?) – Basically, we would like to know, if we need to report for one country or 26 countries.
- Please confirm, what types of transaction should be included in all the points in report where is mentioned Credit Transfers only. We believe that it will be SEPA, INSTANT SEPA, but should it also include SWIFT & SEPA DIRECT DEBIT?
- Please confirm the flow of the transactions for all the points in report where is mentioned Credit Transfers only? (Inbound, Outbound, Both)
- What is the considered to be a Consumer? This is in relation with point 0090 on the S 01.00. We basically would like to know if we need to include all our merchants. (Cause not all of them might be consumers depending on the definition)
- Can you please explain a bit more the definition of the point 0130 & 150, on the S 01.00. We believe we should not have these accounts, just want to confirm.
- What would be the definition of domestic country? Do we go by IBAN (Irish for all our Merchants) or country of Merchant or any other country?
- What would be the definition of cross border transaction for our business? Do we go by IBAN or country of Merchant?
- Point 0450 & 0470 on the S 01.00. – Would that payments include SWIFT?
- Please confirm, who will be initiator of the transactions included in all the points in report where is mentioned Credit Transfers only?
- For Point 0010 on S 03.00 How we define account ( Customer Account held with us, counted as one customer, although he might have multiple payment accounts, or Merchant payment accounts or business accounts where we keep charges ) ?
- What would be the definition of the rejected or upon receipt frozen domestic instant transactions? Would that include internal (PSP MPL - us) or external transactions (PSP other than us), or both?
- Our business migrated customers (started to operate ) in the middle of Year 2023, do we submit empty report for Year 2022?
7. Do you perceive the reporting requirements to be proportionate? Is there information contained in the templates that is overly burdensome to report?
Again: Depending from the answer to the question: How we define reporting country ? If the answer is that we need submit to 26 countries separately, then it is quite big burden for the small company to report.
8. Do you have any other comments on the reporting requirements proposed in this CP?
Can you share questions and answers for these questions from other companies?