Legal background
Art. 5c(1c) of the Instant Payments Regulation (IPR) states that: “where a payment account identified through a payment account identifier specified in point (1)(a) of the Annex provided by the payer is held by a PSP on behalf of multiple payees, additional information allowing the payee to be unambiguously identified may be provided by the payer to the payer’s PSP. The PSP maintaining that payment account on behalf of multiple payees or, where appropriate, the PSP holding that payment account, shall, upon the request of the payer’s PSP, confirm whether the payee indicated by the payer is among the multiple payees on whose behalf the payment account is maintained or held. The payer’s PSP shall notify the payer if the payee indicated by the payer is not among the multiple payees on whose behalf the payment account is maintained or held”. To this end, the attribute AT-C007 (‘Possible additional information about AT-C001 sent by the Requester’) has been included in the VOP scheme rulebook . This additional information represents or relates to a sub-account/virtual IBAN held by the intended Payment Counterparty itself. Funds eventually credited on this subaccount/virtual IBAN are firstly booked on ‘The Payment Account Number of the Payment Counterparty’ (AT-C001) held by the Responding PSP.
VOP scheme rulebook
In the VOP scheme rulebook section 3.6.1, it is mentioned: “Additional information about AT-C001, required to identify the Payment Counterparty and being meaningful to the Requester, to the intended Payment Counterparty and possibly to the Responding PSP. This additional information represents or relates to a sub-account held by the intended Payment Counterparty itself. Funds eventually credited on this subaccount are firstly booked on AT-C001 ‘The Payment Account Number of the Payment Counterparty’ held by the Responding PSP. The information is provided by the Requester or on its behalf to the Requesting PSP in DS-01 (section 3.5.1). This attribute must be passed on in DS-02 (section 3.5.2). The Requesting PSPs should populate the information related to subaccounts in the attribute AT-C007 (“Possible additional information about ATC001 sent by the Requester”). It is up to the Requesting PSPs and/or the Payment Counterparty to instruct/agree with the Requester how to receive this information. This additional information can be of added value for the Responding PSP in formulating its Response to the VOP Request message. It is up to Responding PSP to define how the handle the matching process and how to determine its results (refer to [6]). This attribute shall not be used as an alternative to the attribute AT-E005 ‘The identification code of the Payment Counterparty’.”
Clarifications
The below clarifications provide guidance on how a VOP can be done on a sub-account/virtual IBAN, but it is up to the PSPs to find the best way to comply with the IPR requirements.
1. The Requester has only the sub-account/virtual IBAN information In this case the Requester should populate the sub-account/virtual IBAN information in the creditor account field (IBAN of the beneficiary) which should be mapped in the attribute AT-C001 (‘The Payment Account Number of the Payment Counterparty’) in the VOP request.
2. The Requester has both the master account and sub-account/virtual IBAN information
The information is provided by the Requester (or on its behalf) to the Requesting PSP and must be passed on to the Responding PSP. Usually, the Requester does not know about the sub-account/virtual IBAN but executes what the Payment Counterparty (i.e., the payee) instructed. It is the responsibility of the Payment Counterparty (payee) to instruct the Requester (payer) how to encode a credit transfer.
Dedicated field
In some countries, an agreed dedicated field was determined to include the sub-account/virtual IBAN information in a credit transfer. It could be a standard sub-account field, or the ultimate creditor field (or any other field agreed between the PSPs and their PSUs). In order to allow the execution of the VOP, the Requesting PSP must copy the information provided by the Requester in this agreed dedicated field into the attribute AT-C007 (‘Possible additional information about AT-C001 sent by the Requester’) in the VOP request. It is up to Responding PSP to define how the handle the matching process and how to determine its results (directly or by forwarding the VOP request to the PI/EMI).
No dedicated field
In case there is no dedicated field in the credit transfer for the sub-account/virtual IBAN information, as an alternative, the Remittance Information field could be used. In order to allow the correct execution of the VOP, the Requesting PSP must copy the information provided by the Requester in the Remittance Information into the attribute AT-C007 (‘Possible additional information about AT-C001 sent by the Requester’) in the VOP request. Remark: the Requesting PSP does not know whether the information provided in the Remittance Information is really related to a sub-account/virtual account, therefore it will always copy any information provided in this field in the VOP Request.
It is up to the Responding PSP to assess whether this additional information can be of added value in formulating its Response to the VOP request message (directly or by forwarding the VOP request to the PI/EMI). It is up to Responding PSP to define how the handle the matching process and how to determine its results.