On 18 February 2025, the Dutch Central Bank (De Nederlandsche Bank, DNB) posted an update on the Instant Payments Regulation (IPR). The IPR entered into force on 8 April 2024 and payment service providers (PSPs) needed to comply with a first set of obligations from 9 January 2025, with more to follow. For PSPs authorised to provide their services in the Netherlands, DNB is responsible for monitoring compliance with the IPR obligations and can also take enforcement action in instances of non-compliance.
The IPR aims to promote the use of instant credit transfers (ICTs), both domestically and across borders. In doing so, the IPR aims to make ICTs in euro available to citizens, businesses and institutions holding a payment account in the EU, increasing competition and stimulating development of new payment products throughout the EU.
What are the key obligations?
The IPR prescribes the following key obligations that PSPs must adhere to:
- Offering ICTs
PSPs must ensure that all payment service users (PSUs) in the EU can place payment orders for and receive ICTs in euros. This applies to all payment accounts that PSPs maintain for their PSUs. This service must be available 24 hours a day, every day.
In addition, the cost of an ICT may not exceed the fees charged to the PSUs for other similar types of euro transfers.
- Verification of the payee
PSPs must provide a service ensuring verification of the name of the payee to whom the PSU intends to transfer the credit, free of charge.
If the PSU provides both the payment account identifier and the name of the payee, the PSP must provide a service for matching these details, free of charge. This matching service must be offered immediately after the PSU provides the relevant information about the payee and before the PSU is offered the choice to authorise the transfer.
- Harmonised sanction procedure
The IPR includes specific rules for sanctions screening. PSPs must periodically (at least once every calendar day) verify whether their PSUs are subject to targeted financial restrictive measures. Transaction-based screening is no longer permitted.
- Obligation to submit reports to competent authority
PSPs must report to their competent authority (in this case DNB) on (a) the level of charges for credit transfers, ICT and payment accounts and (b) the share of rejections, separately for national and cross-border payment transactions, due to the application of targeted financial restrictive measures. These rejection reports are to be shared every 12 months by the PSP to the competent authority.
What are the key deadlines?
The deadlines for compliance with the IPR for PSPs in the Netherlands are:
- Since 9 January 2025: PSPs must be able to receive ICTs in euros and must use a harmonised sanctions screening procedure.
- By 9 April 2025: PSPs must inform DNB on the level of charges and on rejections during the period starting on 26 October 2022 until the end of preceding calendar year.
- By 9 October 2025: PSPs must be able to send ICTs and must offer a verification service to ensure the name of the payee corresponds to the IBAN number provided.
- By 9 April 2027: Non-bank PSPs’ (payment and electronic money institutions) can send and receive ICTs.