Dear stakeholders: please send requests regarding the Rulebooks to the European Commission, Rue de la Loi 200, 1049 Brussels, Belgium, copy
In response to the requests of European authorities articulated since the late 1990s, the European Payments Council (), in close dialogue with customer representatives, has developed the Credit Transfer () and Direct Debit () Schemes which are key elements required to realise the Single Euro Payments Area (). To-date, it is the responsibility of the as the Scheme Manager to ensure that the schemes detailed in the and Rulebooks evolve in line with market needs. In this capacity, the has established an open and inclusive change management process as well as a predictable rulebook release schedule, which provides planning and investment security to all stakeholders.
With the adoption of the forthcoming 'Regulation Establishing Technical Requirements for Credit Transfers and Direct Debits in Euro' (the Regulation), the European Commission will assume the responsibility of Scheme Manager.
A payment scheme will have to comply with the technical requirements to be established with the Regulation. The Regulation will give power to the European Commission to amend these technical requirements through so-called delegated acts. In other words, the European Commission will be empowered to rewrite the technical requirements applicable to the and Rulebooks at its discretion. Approval of any such amendments by the European Union (EU) legislative bodies; i.e. the European Parliament and the Council representing EU Member States, is not required.
It remains the objective of the that the Rulebooks evolve in response to proven market needs and reflect a broad consensus among all stakeholders. In addition, the will continue to aim for a predictable rulebook release management. The must however clarify to all stakeholders that it can no longer be held accountable in this regard. The will have to ensure that the and Schemes are aligned with the technical requirements to be defined by the European Commission. stakeholders will have to implement operational changes to the and Schemes according to the timelines mandated by the European Commission.
The also wishes to point out that stakeholders should not assume that the European Commission will respond to the requirements of payment service users as identified through market research and public consultations carried out by the . As has been demonstrated during the legislative process leading to the imminent adoption of the Regulation, the European Commission reserves the right to rewrite the Schemes based on its own assessments. For details on the matter, refer to the article ' Regulation: Last Call to Legislators' (see 'related articles in this issue' below).
The is committed to make every effort to engage in constructive dialogue with the European Commission and would therefore like to offer some insight on industry best practice regarding effective scheme management and rulebook release management.
The principles governing the evolution of the Schemes established by the
The payment schemes as set out in the and Rulebooks include the Scheme Management Internal Rules (see 'related links' below) which define the change management process applicable to the rulebooks. The annual Scheme change management cycle implemented by the leads to the publication of updated versions of the scheme rulebooks every November. The first step in the annual scheme change management cycle is the introduction of suggestions for changes to the schemes by any interested party. All stakeholders are invited to submit suggestions for changes to the by the end of February each year.
In consideration of the suggestions received, the Payment Schemes Working Group (SPS WG) develops a single consolidated change request document per rulebook. The preparation of the change request involves analysis of the suggestions for changes received, including a cost-benefit analysis where appropriate, dialogue with the initiator and, if appropriate, market research. Based on this analysis, the SPS WG decides whether to accept a suggestion for change or not.
Initiators of any suggestions for changes are notified of the decision taken by the SPS WG. All recommendations to modify the rulebooks received by the - irrespective of whether they have been accepted into the change management process - are published on the website, permitting such a list to be openly viewed by all stakeholders. The change requests are released for a three-month public consultation in May of each year. Taking into account comments received during the consultation, the SPS WG completes a change proposal for approval by the Plenary every September. Proposed changes to the Schemes that find broad acceptance in the entire user community are incorporated into the new rulebook versions - regardless of whether such a change is proposed by a payment service provider () or customer representatives. Change requests that lack such broad support are not.
The publishes in full all feedback received from any public consultation on the evolution of the Schemes on the Website.
Scheme Rulebook Release Management
To ensure the proper functioning of the euro payments market, which processes some 71.5 billion electronic euro payments annually, it is imperative that and their customers comply with the same version of applicable scheme rulebooks at any given time.
Providing planning security for all market participants and coordinated transition to amended scheme rulebooks, publication of new rulebook versions follows a predictable release management cycle. In accordance with industry best practice, and their suppliers have a one-year lead time to address rulebook updates prior to such updates taking effect. The releases amended versions of the rulebooks once annually in November of each year. The updated versions of the rulebooks will then take effect in the third week of November of the following year to allow for alignment with SWIFT message releases.
The ensures maximum awareness and engagement of all stakeholders in the scheme change management process
The has a proven track record of consulting stakeholders on its deliverables including the evolution of the and Rulebooks. The principles governing scheme development as outlined above are highlighted on prominent sections of the Website dedicated to the information needs of bank customers (see 'related links' below). The Newsletter features in every issue an article which updates on the next stage in the annual scheme change management process and urges all stakeholders to engage (see 'related articles in previous issues' below). To ensure maximum transparency and awareness, the publishes a press release to alert stakeholders on the annual public consultation addressing modifications that may be introduced into the and Rulebooks (see 'related links' below).
Last but not least, the greatly appreciates the dialogue taking place in the Customer Stakeholders Forum (CSF) established in 2007. CSF members represent a wide cross-section of interest groups acting at the European level including consumers, corporate and small and medium sized enterprises. The CSF is co-chaired by a representative of the demand side and the Chair. The CSF specifically addresses the requirements of payment service users with regard to the and Schemes. The assumption is that CSF members representing the customer side engage in close dialogue with their member organisations representing bank customers at a national level. The 32 banking communities represented in the are under the obligation to ensure proper stakeholder consultation at a national level during the annual public consultation on possible modifications to the Schemes.
The calls on lawmakers to align the forthcoming Regulation with industry best practice regarding scheme development
The calls on the legislator to align the forthcoming Regulation with current best industry practice regarding scheme development and rulebook release management. When exercising its delegated powers to amend the technical requirements applicable to the and Schemes, the European Commission must ensure that this process is based on extensive market consultation and broad consensus among all stakeholders. Also going forward, both the demand and supply sides must be able to rely on sufficient lead times to implement changes to Schemes as mandated by the European Commission.
The authorities should keep in mind that adapting the systems of some 4,000 participating in the Schemes, as well as those of millions of businesses and public administrations on the customer side, is a complex process to ensure the highest level of compliance, interoperability and security.
Javier Santamaría is the Chair of the Payment Schemes Working Group.
Related articles in this issue:
Related articles in previous issues:
What is Your View? EPC invites stakeholders to participate in consultations on the SEPA Scheme Rulebooks and the SEPA Cards Standardisation Volume - Book of Requirements ( Newsletter, Issue 11, July 2011)
SEPA Scheme Change Management - Public consultation starts in May 2011 ( Newsletter, Issue 10, April 2011)
SEPA Scheme Change Management 2011 - Call to Stakeholders. Suggestions for changes to SCT and SDD must reach the EPC by end February 2011 ( Newsletter, Issue 9, January 2011)
SEPA Schemes: Next Generation. EPC publishes new versions of the SCT and SDD Rulebooks on 1 November 2010 ( Newsletter, Issue 8, October 2010)
SEPA Scheme Rulebooks: next Release. Public consultation ends in August 2010 ( Newsletter, Issue 7, July 2010)
SEPA Scheme Change Management 2010: Public Consultation. All stakeholders are invited to participate in the evolution of the SEPA Schemes ( Newsletter, Issue 6, April 2010)
SEPA Scheme Change Management Cycle 2010. Suggestions for changes must reach the EPC by end February 2010 ( Newsletter, Issue 5, January 2010)
New SEPA Scheme Rulebooks out now. EPC publishes new versions of the SCT and SDD Rulebooks on 1 November 2009 ( Newsletter, Issue 4, October 2009)
Rock the Vote. Public consultation on SEPA scheme development is going on now ( Newsletter, Issue 3, July 2009)
The Preview. Rulebook Release Management 2009 ( Newsletter, Issue 2, April 2011)
SEPA Schemes: EPC approves Release Schedule. Predictable release cycle ensures planning security ( Newsletter, Issue 1, January 2009)
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