The VOP process presents a challenge for certain factoring solutions, specifically those involving "half-disclosed factoring”, since in these cases, the payer is unaware of the factoring process and only receives an invoice from the payee that is known to the payer, instructing payment to an account (IBAN) that belongs to the factoring company. The payer is thus initiating a payment to the factoring company directly but with the name of the payee, without knowledge of the assignment.
The IPR does not recognize an exemption for factoring from the VOP process.
The issue is similar for the collection on behalf companies.
Generic guidance cannot be provided in this case, and the VOP Working Group recommends to the factoring companies to address this topic directly with their respective PSPs. Similarly, collection on behalf companies should address this topic directly with their customers and/or their PSPs.