Response to consultation on proposed RTS in the context of the EBA’s response to the European Commission’s Call for advice on new AMLA mandates
Question 3: Do you have any comments regarding Article 8 on virtual IBANS? If so, please explain your reasoning.
The Standards Advisory Group (SAG) of Technical Committee 68 of the International Organization for Standardization (ISO) TC 68/AG2 notes that the IBAN (International Bank Account Number, ISO 13616) standard is undergoing systematic review. ISO standards undergo review every five years to determine if they remain current and relevant.
The review is focusing on:
- Evaluating the standard's effectiveness in an increasingly digital payment landscape
- Assessing the need for additional validation rules to accommodate evolving payment technologies
Financial institutions and payment systems operators are participating actively in the review process, with final results expected to be published in early 2026. It is now an appropriate time to consider any enhancements to the IBAN standard to be raised and included as part of this review process that may help facilitate improved identification and management of virtual account numbers.
The SAG remains at your disposal to further discuss and support you in your work. Do not hesitate to engage us in your discussions and questions related to standards in financial services.
Question 6: Do you agree with the proposals as set out in Section 4 of the draft RTS? If you do not agree, please explain your rationale and provide evidence of the impact this section would have, including the cost of compliance, if adopted as such?
The SAG welcomes the explicit inclusion of the LEI (Legal Entity Identifier, ISO 17442) as part of the information to be collected for customer due diligence purposes in the context of the draft RTS under Article 28(1) of the Anti-Money Laundering Regulation (AMLR).
The inclusion of the LEI in the draft RTS is of course consistent with the Level 1 Regulation Article 22 which stipulates legal entities to disclose their LEI, where available, as part of the customer onboarding process.
As an interoperable, machine-readable standard, the LEI can facilitate counterparty verification mechanisms and reduces the need of using multiple jurisdiction-specific identifiers, in turn facilitating administrative processes for businesses operating at an international scale.
The SAG also will respond to RTS under Article 28(1), Question 3: Do you have any comments regarding Article 8 on virtual IBANS? If so, please explain your reasoning.