What is to be filled in the field “Readiness Date”?
The Readiness Date (or Effective Date) is the date by which a Participant will effectively adhere to a Scheme.
Is it necessary to state in the Adherence Agreement or in the Schedule whether my organization will act as a Debtor PSP and / or as a Creditor PSP under one or both of the SEPA Direct Debit Schemes or whether my organization offers optional features defined in the SDD Rulebooks?
No, Applicants will not indicate in the adherence documents whether they act as a Debtor PSP or as a Creditor PSP under one or both of the SEPA Direct Debit Schemes.
My organisation currently does not offer any product or service allowing customers to originate instant credit transfers, and we want to adhere to the SCT Instant Scheme as a Beneficiary PSP. Are we now obliged to be an Originator PSP?
A PSP may adhere to the SCT Instant Scheme in the capacity of a Beneficiary PSP only, capable of receiving Scheme payments.
What happens if there is no NASO established in my country when I wish to submit my Adherence Pack?
In this situation, the PSP should submit its Adherence Pack directly to the EPC Secretariat.
My organisation wishes to consult a NASO. However, my organisation is signing an adherence agreement as an Agent on behalf of subsidiaries located in various different SEPA jurisdictions. Does this mean that my organisation must consult the NASO in each of the jurisdictions where a subsidiary is located?
No. Where subsidiaries are located throughout SEPA, it is not necessary to consult a NASO in each of the countries where a subsidiary is located.
The EPC Payment Scheme Management Rules mention NASOs. Is my organisation obliged to use a NASO?
In general, Applicants are expected to first consult a NASO before submitting their application to the EPC.
If my organisation signs up to a Scheme on its own behalf and on behalf of another legal entity (e.g. a subsidiary), will my organisation have any legal responsibility if this legal entity fails to comply with its obligations under the Rulebook?
No. The underlying obligations under the Scheme are the responsibility of the adhering PSP only and not the Agent.
If yes, what must each of my association's members be required to do to permit the national PSP association to sign up to the Scheme on their behalf and what documentation is required?
See response to Question 9.
I represent a national PSP association. Can my organisation sign up to the Scheme on behalf of all of my association's members?
Yes, the organisation can act as an Agent on behalf of its members, subject to the foregoing provisions.
If yes, what will each PSP be required to do to permit another PSP to sign up to the Scheme on its behalf and what documentation is required?
If a PSP or an association signs as Agent on behalf of another, the two parties must have taken the necessary legal steps to establish the necessary authority for the agency arrangement.