Background
The European Payments Council's (EPC) Verification Of Payee (VOP) scheme is a standardized framework designed to enhance payment security across the Single Euro Payments Area (SEPA). It aims to reduce fraud and misdirected payments by verifying that the payee's name matches the account number provided before a payment is executed.
When a requester (the payer) initiates a SEPA Credit Transfer (SCT) or SEPA Instant Credit Transfer (SCT Inst), its Payment Service Provider (PSP), the requesting PSP, sends a VOP request to the payee's PSP (the responding PSP). This request includes the payee's International Bank Account Number (IBAN) and either its name or an identifier such as a VAT number or Legal Entity Identifier (LEI).
The payee's PSP (the responding PSP) checks the provided information against its records and responds with one of the following answers:
- Match: The name (or identifier) and IBAN correspond exactly.
- Close Match: There are minor discrepancies, such as typographical errors.
- No Match: The details do not correspond.
- Verification Not Possible: The check cannot be completed.
The payer's PSP (the requesting PSP) communicates the result to the requester (the payer), who can then decide whether to proceed with the payment or not.
Under the EU Instant Payments Regulation (IPR), a VOP service must be implemented by 9 October 2025 for all Euro payments between PSPs located in the EU/EEA.
With regard to the processing of bulk files, Art. 5c(6) of the Instant Payments Regulation (IPR) states that:
“PSPs shall provide PSUs that are not consumers with the means to opt out from receiving the service ensuring verification when submitting multiple payment orders as a package.
PSPs shall ensure that PSUs that opted out from receiving the service ensuring verification have the right to opt in at any time to receive that service.”
Further explanations in relation with the processing of VOP for batch files were also provided in the Clarification by the European Commission of the requirements of the Instant Payments Regulation (questions 117 to 120).
The processing of VOP for bulk files is out of the scope of the VOP scheme. In the inter-PSP space, a VOP request always concerns a single verification of one payment account number (IBAN).
The VOP scheme rulebook section 3.2, only mentions that: “In the PSU-to-PSP Space, the Requester and the Requesting PSP may agree to exchange several Requests as single items or as a bulk VOP Request.”
Clarifications
The below clarifications provide guidance on the provision of VOP-services for bulk files.
Preliminary remarks:
- The obligation to offer VOP-services for bulk files lies on the PSPs.
The corporates are not obliged to make use of these services and can opt-out. - PSPs are obliged to offer VOP-services for bulk files but may decide how to offer these. They are not obliged to offer these through the same technical channel or according to the same process used for the processing of bulk payment orders.
This means that VOP-services for bulk files could for example be offered by PSPs through a 2-step approach or through a 1-step with exceptions management, or in any other way. - The processing of VOP for bulk files has an impact not only on the PSPs but also (and mainly) on the corporate users, which will have to adapt their internal payment processes, interfaces and IT tools, e.g. to handle situations where the result of the VOP is ‘Close Match’, ‘No Match’ or ‘Verification check not possible’. PSP are advised to discuss this with their corporate customers and come to a joint decision on which would be the right moment when both sides are ready for the processing of VOP for bulk files.
- For corporate users there is neither an increased liability or risk with VOP nor the possibility to benefit from a “liability shift” towards the respective PSPs, since (1) in general, the distribution of liability across the value chain does not change with VOP, and (2) in case of opt-out from the VOP-services for bulk files, the lists of existing IBANs which have been successfully used so far by corporate users, can still be trusted by them. In general, whenever a corporate user authorises a payment, whether after receiving and processing the result of a VOP request, or after opting-out from VOP-services for bulk files, the corporate user remains the liable party.
Considering all the above remarks, and considering that a preliminary analysis carried out in 2024 by the EPC did not allow to identify a clear solution acceptable by the majority of the SEPA communities to standardise the processing of VOP for bulk files in the Customer-to-PSP (C2PSP) space, the EPC decided to halt the work on this standardisation and to wait for a consolidation of market requirements and solutions adopted by SEPA communities.
The EPC’s VOP Working Group is expected to restart an analysis in June 2025. The timeline for completing this analysis and to (potentially) standardise the processing of VOP for bulk files in the C2PSP space, will be communicated at a later stage.