The published its response to the European Commission's proposal for a regulation of the European Parliament and of the Council establishing technical requirements for credit transfers and direct debits in euros and amending Regulation (EC) No 924/2009 published on 16 December 2010 (the 'proposal'). The response is set out in the documents featured on this page.
The welcomes the European Commission's willingness to legislate on end dates for migration to payment schemes. The shared understanding throughout the past decade is that this process aims at replacing national euro payment schemes by the Credit Transfer () and Direct Debit (SDD) schemes developed by the in close dialogue with the user community. The has however several concerns regarding the proposal for the forthcoming regulation which are set out in the documents posted here.
Version 1.0 of the response to the proposal was published in February 2011. Version 2.0 of this response is published in March 2011. The detailed comments on the proposal are set out in the document EPC467-10. The executive summary of the response is set out in the document EPC468-10. Both these documents were updated in March 2011.
The two additional documents posted on this page (EPC017-11 and EPC038-11) are supporting documentation providing background information on positions taken with regard to the proposal. These documents remain unchanged.
Following further evaluation of the possible implications of the proposal on the Direct Debit business model, the Plenary at its meeting on 23 March 2011 adopted the position
- that article 6 (and related articles and recitals) should be removed from the proposal,
- and that the 'November 2012' date mentioned in Regulation (EC) No 924/2009 should be removed from that regulation.
A summary of the arguments supporting the position with regard to article 6 (interchange fees for direct debit transactions) of the proposal is included in section 1 of the executive summary of the response to the proposal (EPC468-10, see below).
1. EPC468-10: AN UPDATE - Executive Summary of the Response to the Proposal for a Regulation
2. EPC467-10: AN UPDATE - Response to the Proposal for a Regulation
3. EPC038-11: 'Interoperability of Payment Schemes Is Not Feasible'. This document provides background information relevant to the 's recommended amendments of article 4 (2) of the proposal which envisages the obligation to create interoperability of payment schemes.
4. EPC017-11: 'The Principles Governing the Direct Debit Core Scheme'.This document provides background information relevant to the 's recommended amendments of section 3 of the annex to the proposal (technical requirements applicable to direct debit transactions).
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