On 26 October 2022, the European Commission proposed a new regulation to make instant payments available throughout the EU. The proposal requires all payment service providers (PSPs) to set up systems that allow their customers to send and receive instant payments. Although this improves the efficiency of payments, the proposal may place an excessive burden on smaller organisations and create potential money laundering risks.

The ABBL calls for a change in the implementation timetable in general, and in particular with regard to the obligation for all banks to perform free IBAN/name checks for their customers. During the debate in the European Parliament, most legislators supported this requirement, citing the successful implementation in the Netherlands. However, there is no equivalent database in other Member States and sufficient time needs to be allowed to develop such a solution.

The ABBL also calls for a reasonable exclusion from the requirements for all transactions/activities involving the high risk factors listed in the AML Directive. This exclusion will ensure that due diligence requirements remain the top priority in these types of transactions. As negotiations on this regulation are ongoing, the ABBL is actively engaged in dialogue with the EU institutions to promote these changes.

The Council of Member States and the European Parliament are expected to adopt their respective positions on the law by the summer. Following inter-institutional negotiations, the regulation could enter into force before the end of the year. 

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ABBL Adviser, European Affairs



Digital Banking and Payments Adviser