The EPC cannot provide any legal advice about compliance with legal regulations. Each scheme participant and market operator (including RVMs) must conduct their own compliance evaluations.
The following should be taken into consideration, though:
Article 5c of the Instant Payment Regulation (IPR) defines the conditions for the Verification of Payee. It states VOP cannot be decoupled from a payment transaction:
“A payer’s PSP shall offer the payer a service ensuring verification of the payee to whom the payer intends to send a credit transfer. The payer’s PSP shall perform the service ensuring verification immediately after the payer provides relevant information about the payee and before the payer is offered the possibility of authorising that credit transfer.”
There are valid scenarios where a payment is registered ahead of its execution, e.g., when a client enters a future-dated payment. In such cases, VOP is performed at the time of registration, before authorisation of the payment by the client. Please note that no expiry period is defined for a VOP.
However, this does not apply to the scenario where a corporate onboards a new vendor in its ERP system as at this moment no concrete payment transaction is initiated. Verification of Payee would only be performed when the first payment is initiated to this vendor and for each subsequent payment; provided the corporate does no opt out of VOP.