SEPA - National Migration Plan

NATION AL SEPA
M IG RATION PL AN
November 2012
Lisbon, 2013
www.bportugal.pt
Banco de Portugal
EUROSYSTEM
BANCO DE PORTUGAL
Av. Almirante Reis, 71-7.º
1150-012 Lisboa
www.bportugal.pt
Edition
Payment Systems Department
Translation
International Relations Department
Translation Unit
Design, printing and distribution
Administrative Services Department
Documentation, Editing and Museum Division
Editing and Publishing Unit
Lisbon, 2013
ISBN 978-989-678-241-2 (on-line)
ÍNDICE
5
I. PLAN OBJECTIVE
6
II. SCOPE AND APPROACH
7
III. SUMMARY OF EU REGULATION NO 260/2012
9
IV. MIGRATION CONSTRAINTS
11
V. MIGRATION ACTIVITIES
11
5.1 Stakeholders perspective
13
5.2 Payment instruments perspective
15
5.3 Integrated perspective
16
5.4 Migration goals
17
VI. PLAN MONITORING
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Annex 1 | Composition of the payment systems forum
19
Annex 2 | Questionnaires
26
Annex 3 | Analysis of responses to the questionnaires
31
Annex 4 | 50 largest credit transfer payers
32
Annex 5 | 30 largest direct debit creditors
I. PLAN OBJECTIVE
The main objective of this National SEPA Migration Plan is to ensure a timely, gradual and efficient
pursuant to Regulation (EU) No 260/2012 of the European Parliament and of the Council.
Hence, from that date onwards, all payments carried out through credit transfers and direct debits shall
comply with SEPA technical requirements.
It has been possible to carry out SEPA credit transfers and SEPA direct debits in Portugal since 28 January
2008 and 1 November 2010 respectively.
However, in September 2012 only 38.4% of total transfers originated in Portugal and 0.16% of direct
debits were performed in SEPA format, compared with European averages of 28.2% and 0.49% (data
for May) respectively.
These indicators show that migration to SEPA has been quite slow in Portugal, particularly with regard
to direct debits.
An urgent and significant effort is therefore required from all stakeholders involved in providing payment
instruments (central bank, payment service providers, corporates, software suppliers and other payment
service providers), for whom this Plan is intended to be a working reference.
By defining a series of migration activities, timelines and goals, the National SEPA Migration Plan aims
to accelerate the migration process in Portugal and subsequent compliance with the provisions of
Regulation (EU) No 260/2012.
The Plan is organised as follows:
• Chapter 2: description of the scope and assumptions followed in the preparation of the Plan;
• Chapter 3: presentation of the main requirements laid down in Regulation (EU) No 260/2012 of the
European Parliament and of the Council;
• Chapters 4 and 5: identification of migration constraints and detailed definition of activities to be
carried out by the various stakeholders aimed at a timely, gradual and efficient migration to SEPA
credit transfers and direct debits in Portugal;
• Chapter 6: description of mechanisms both to follow the implementation of activities envisaged
in the Plan and monitor compliance with established migration goals.
I
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Plan Objective
migration to SEPA credit transfers and direct debits in Portugal, to be completed by 1 February 2014
II. SCOPE AND APPROACH
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The National SEPA Migration Plan establishes a series of activities, timelines and goals aimed at ensuring
a timely, gradual and efficient migration to SEPA credit transfers and direct debits by 1 February 2014.
The approach adopted to prepare this Plan relies on the following assumptions:
• Migration should be gradual, thus minimising operational and credibility risks that could stem
from inadequate preparation of systems for a ‘big-bang’ migration on the end-date and subsequent
impact on user confidence in the operation of payment systems. Payment service providers (PSPs)
are better prepared to support a gradual migration of their (private or corporate) customers, thus
promoting a step-by-step process. This gradual migration is particularly relevant in the case of large
businesses originating a high number of payments. Migration to SEPA should therefore start with
these privileged partners in an approach involving pilots and testing periods clearly defined in an
appropriate timeline.
• All stakeholders involved in providing payment instruments should cooperate in the
migration effort (central bank, PSPs, corporates, public administrations, software suppliers and
other service providers active in the payments domain).
The Comissão Interbancária para os Sistemas de Pagamentos (Payment Systems Interbank
Commission) and the Fórum para os Sistemas de Pagamentos (Payment Systems Forum),1 which
includes a SEPA Steering Committee, will greatly contribute to fostering dialogue, establishing
commitments and promoting the necessary cooperation among these stakeholders.
Given the role and needs of each plan stakeholder, the following sub-groups should be considered:
PSPs, public administrations, main corporate users (senders) of credit transfers, main corporate users
(creditors) of direct debits and consumers.
Taking into account the interconnections between different stakeholders, a cascade approach
should be adopted (i.e. the migration of a small number of large businesses will in turn allow for
the migration of a high number of small users).
• The types of activities to be carried out should be diversified and suited to the role played
by each stakeholder in the provision of payment instruments, taking into account their degree
of preparedness and the necessary steps they are responsible for in the migration process.
• The types of activities to be carried out should be different for credit transfers and direct
debits. On the one hand, corporates using credit transfers have different characteristics
and needs from corporates using direct debits, and on the other hand, SEPA credit transfers
are simpler and have been available for longer than SEPA direct debits.
• After the migration end date to SEPA credit transfers and direct debits, legacy instruments/
schemes will be discontinued.
1 The Payment Systems Forum is an advisory structure of Banco de Portugal created in October 2009 and composed of representatives of
the national banking community and the main users of retail payment instruments, such as consumer associations, public administrations and the corporate sector. The entities comprised in this Forum are shown in Annex 1.
III. SUMMARY OF REGULATION NO 260/2012
This Regulation does not apply, inter alia, to the following (see Article 1(2)):
• payment transactions carried out between and within PSPs, including their agents or branches,
for their own account;
• payment transactions processed and settled through large-value payment systems (such as TARGET2),
excluding direct debit payment transactions which the payer has not explicitly requested to be routed
via a large-value payment system;
• payment transactions through a payment card or similar device, including cash withdrawals, unless
the payment card or similar device is used only to generate the information required to directly
initiate a credit transfer or direct debit to and from a payment account identified by BBAN or IBAN;
• payment transactions by means of any telecommunication, digital or IT device, if such payment
transactions do not result in a credit transfer or direct debit to and from a payment account
identified by BBAN or IBAN.
First, under the Regulation, PSPs shall carry out credit transfer and direct debit transactions in accordance
with the following technical requirements (Article 5 of the Regulation jointly with the Annex):
• they must use the IBAN for the identification of payment accounts regardless of the location of the
PSPs concerned [Article 5(1)(a)].
• they must use the ISO20022 XML standard when transmitting payment transactions to another
PSP or via a retail payment system [Article 5(1)(b)]. This standard means that technical conversion
services to the ISO20022 XML format may not be used at the interbank level2.
• they must ensure that Payment Service Users (PSUs) use the IBAN for the identification of payment
accounts, whether the payer’s PSP and the payee’s PSP or the sole PSP in the payment transaction
are located in the same Member State or in different Member States [Article 5(1)(c)].
• they must ensure that where a PSU that is not a consumer or a microenterprise, initiates or receives
individual credit transfers or individual direct debits which are not transmitted individually, but are
bundled together for transmission, the ISO20022 XML standard is used. PSPs shall, upon the specific
request of a PSU, use the ISO20022 XML standard in relation to that PSU [Article 5(1)(d)].
In this case, the PSU shall receive the transaction processing report, sent by its PSP, based on the
same ISO20022 XML format (thus enabling both automatic reconciliation and e-invoicing).
Technical conversion services to the ISO20022 XML format may be offered to PSUs obliged to use
this standard when transmitting credit transfers or direct debits bundled together, provided this
conversion is carried out before the payment is initiated (for corporates). The purpose of this is to
use the ISO20022 XML format throughout the payment chain (end-to-end) and not just at the
interbank level (between PSPs). These technical conversion services may be offered by software
suppliers or PSPs engaged by corporates for that purpose.3
• After 1 February 2014 for national payment transactions and after 1 February 2016 for cross-border
payment transactions PSPs shall not require PSUs to indicate the BIC of the PSP of a payer or of the
PSP of a payee [Article 5(7)].
2 See also the report by the European Central Bank of the meeting that took place on 30 March 2012 with European Commission experts
to clarify the requirements set out in Regulation (EU) No 260/2012.
3 Idem.
III
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Summary of eu Regulation No 260/2012
Regulation (EU) No 260/2012 of the European Parliament and of the Council of 14 March 2012 establishes
technical and business requirements for credit transfers and direct debits in euro in the European Union.
The Regulation also stipulates that by 1 February 2014 at the latest, credit transfers and direct debits
shall be carried out in accordance with these technical requirements (see Article 6(1) and (2)).
III
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In addition, intrabank transfers (i.e. between accounts within the same PSP) are covered by this Regulation
and are subject to the use of the IBAN as payment account identifier. Nevertheless, these transfers are
not required to be carried out using the ISO20022 XML standard.
As regards the business requirements, pursuant to the Regulation, no multilateral interchange fees
shall apply to direct debit transactions from 1 February 2017 for national payments and 1 November
2012 for cross-border payments (see Article 6(3)). However, a multilateral interchange fee may be applied
to transactions which are rejected, refused, returned, reversed, revoked or whose cancellation is requested
provided that certain conditions are complied with (see Article 8(2)).
Finally, pursuant to the Regulation, Member States may decide on a number of transitional measures.
Hence, up to 1 February 2016, Member States may:
• allow PSPs to provide PSUs with technical conversion services for national payment transactions
enabling PSUs that are consumers to continue using the payer’s and the payee’s BBAN instead
of the respective unique payment account identifier (IBAN). That payment account identifier shall
be delivered to the initiating PSU, where appropriate before the payment is executed. PSPs shall not
levy any direct or indirect charges or other fees linked to that service (see Article 16(1)).
• allow their competent authorities to waive all or some of the established requirements for those
credit transfer or direct debit transactions with a cumulative market share of less than 10% of the
total number of credit transfers or direct debit transactions respectively, in that Member State (based
on official payment statistics published annually by the ECB) (see Article 16(3)).
• allow their competent authorities to waive the use of the ISO20022 XML message format for PSUs
which initiate or receive individual credit transfers or direct debits that are bundled together for
transmission. Notwithstanding a possible waiver, PSPs shall use this format where a PSU requests
it (see Article 16(5)).
• defer the provision of BIC for national credit transfer and direct debit transactions (see Article 16(6)).
As regards the monitoring of its implementation and penalties applicable to infringements, the Regulation
also lays down that Member States shall designate the competent authorities responsible for ensuring
compliance with the Regulation, lay down rules on the penalties applicable to infringements of the
Regulation and establish adequate and effective out-of-court complaint and redress procedures for the
settlement of disputes between PSUs and PSPs (see Articles 10, 11 and 12).
Given the legislative options and measures that must be defined and implemented to ensure a smooth
and effective execution of Regulation (EU) No 260/2012, Banco de Portugal is working on a draft
decree-law envisaging the measures needed to implement this Regulation, in order to comply with the
end-date of 1 February 2013 for notification to the European Commission.
IV. 4. MIGRATION CONSTRAINTS
of total transfers originated in Portugal and 0.16% of direct debits were in SEPA format. What accounts
for these migration indicators?
There are numerous reasons for this: (i) inertia to change on the part of all stakeholders; (ii) non-existence
of the necessary technical/technological requirements on the part of PSPs; (iii) lack of commercial/
promotional capacity on the part of PSPs, which still do not have SEPA products ‘packaged’ for retail
customers; (iv) absence of functionalities that are deemed important in SEPA schemes in force, compared
with legacy schemes; (v) need for clarity in the migration timeline, now established by Regulation (EU)
No 260/2012 of 14 March 2012.
To better understand the reasons underlying the weak SEPA migration indicators in Portugal and
consequently to draw up a National Migration Plan that effectively responds to these obstacles, Banco
de Portugal has conducted a questionnaire among PSPs, public administrations and corporates represented
in the Payment Systems Forum and certain software suppliers (see Annex 2).
Responses to the questionnaire are summarised in the boxes below. For a more detailed analysis, please
refer to Annex 3.
Payment service providers
PSPs claim to be aware of the legal requirements of Regulation (EU) No 260/2012 and to have enough
information on SEPA.
Internal implementation of the processing of SEPA payment instruments is not yet complete in a
significant percentage of PSPs, especially as regards direct debits. Notwithstanding most PSPs reporting
they will complete this process in the course of 2013, there are still a significant number that point to
January 2014 as the date they will make SEPA instruments available.
Most PSPs still do not present SEPA payment instruments by default when a customer intends to carry
out a payment transaction. PSPs cited the following as the main difficulties faced by their customers:
(i) complexity of migration to the new formats; (ii) difference in treatment between legacy credit transfers
and SEPA credit transfers (e.g. salary processing and fund provision); and (iii) perception that SEPA credit
transfers are not yet stabilised.
Among the suggestions sent by PSPs, the following are particularly relevant: (i) a proposal to define/
release end-dates for migration to new payment instruments; and (ii) the organisation of stakeholder
information and briefing sessions, especially through the media.
IV
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Migration constraints
The following is the starting point for this National Migration Plan: as at September 2012, 38.4%
Payment service users
Most payment service users or ‘PSUs’ (public administrations and corporates) report having enough
IV
information on SEPA, claiming to be aware of the customer-to-bank communication manual (C2B –
sample used includes the main credit transfer issuers and direct debit initiators in Portugal. The reality
BANCO DE PORTUGAL | NATIONAL SEPA MIGRATION PLAN
Customer to Bank Services) and Regulation (EU) No 260/2012. This may be due to the fact that the
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is probably very different for small and medium-sized enterprises (SMEs) and the degree of information
and preparation for SEPA considerably lower.
Still, a small number of PSUs report they are not aware of a need to change their internal systems.
A significant percentage of respondents reported using SEPA payment instruments, mainly credit
transfers, although not exclusively (i.e. SEPA products together with legacy solutions). This stems from
the belief that not all PSPs are prepared for transaction processing in SEPA format and from the need
for additional technical developments.
Most PSUs intend to complete the migration process to SEPA payment instruments during 2012.
In the case of direct debits some PSUs have declared the intention of completing their migration to SEPA
by the third quarter of 2013.
Software suppliers
Software suppliers are aware of the customer-to-bank communication manual (C2B – Customer to
Bank Services) and the technical and business requirements set out in Regulation (EU) No 260/2012.
A considerable proportion of respondents claimed they currently have commercial solutions for SEPA
credit transfers and direct debits (‘packaged’ or ‘tailored’). Software suppliers that do not yet provide
their own solutions stated that they plan to do so by the first half of 2013 at the latest.
Among the suggestions received, the following are particularly relevant: (i) creation of working groups
with suppliers of IT system products/services, so as to raise awareness and enhance their responsiveness
to the needs of stakeholders; (ii) outline of a ‘General Guidance Programme’ with initiatives to integrate
domestic systems into SEPA schemes; and (iii) implementation of a governance model to monitor such
activities and ensure they are implemented, which should encourage PSPs to proactively anticipate
the migration of customers and volumes to SEPA.
The following conclusions may be derived from the combination of responses by the inquired stakeholders:
• Great importance is attached to SEPA communication, information and awareness-raising activities.
• In order to make the migration process successful, it is essential that a National Migration Plan
is managed and monitored.
• There is a risk of the migration not being sufficiently gradual, as some PSPs will only have their
internal systems duly adapted by January 2014.
• There is misalignment between planning at PSP and PSU level, since corporates intend to complete
the migration of credit transfers in 2012 and of direct debits by the third quarter of 2013 and many
PSPs only intend to have SEPA instruments fully available in January 2014.
V. MIGRATION ACTIVITIES
below, both from the perspective of the different stakeholders and in terms of credit transfer and direct
debit instruments.
5.1 Stakeholders perspective
As far as stakeholders are concerned, the type of activity to be carried out should be diversified and
suited to the role each plays in providing/using payment instruments.
5.1.1 Payment service providers
First, it is the responsibility of payment service providers (PSPs) to ensure that the necessary technical
and business requirements are fulfilled for conducting credit transfers and direct debits in SEPA format.
These technical and business requirements are defined in the SEPA Credit Transfer and Direct Debit
Scheme Rulebooks and their Implementation Guidelines published by the European Payments Council (EPC)
and Regulation (EU) No 260/2012.
With a view to facilitating the connection between major customers and their PSPs, the Portuguese
banking community has also developed a standardised format for customer-to-bank communication
(C2B – Customer to Bank Services) applicable to SEPA credit transfers and direct debits.4 This C2B
standardised format brings clear benefits, especially for corporates and public administrations, notably as
it: (i) prevents multiple formats from being used by customers in their relationship with banks to initiate
payment instructions; and (ii) offers customers a cost-efficient communication solution.
The existence of technical and business requirements is a key condition for migration to SEPA and will
allow a cascade approach: at a first stage a small number of major public and private sector entities are
expected to migrate (early movers), followed by a high number of small users. This approach assumes early
movers will receive strong support and will address any problems from the outset relating to processing
a high volume of payments (as shown by the lesson drawn from the process of migrating social security
payments to the SEPA format – see box below). Hence, to assist public and private sector entities in this
adaptation process, the drawing up of a ‘migration guide’ for SEPA credit transfers and direct debits
is particularly relevant. This guide, jointly drawn up by the Interbank Working Groups on credit transfers
and direct debits, includes a description of the steps and requirements needed to carry out the migration
for the respective SEPA instruments.
According to the previously mentioned approach, PSPs should take the initiative to address at least two
of the main credit transfer payers5 and two of the main direct debit creditors,6 preferably entities that
are represented in the Payment Systems Forum (either directly or through associations) to draw up pilot
programmes for migration to SEPA. These pilots must envisage timelines for development, testing periods
and actual migration, always taking into account that the preparation process to use SEPA credit transfer
and direct debit schemes might take longer than expected.
4 Available at Banco de Portugal’s website: http://www.bportugal.pt/en-US/pagamentos/SEPA/RegrasdeFuncionamento/Pages/inicio.aspx
5 See Annex 4.
6 See Annex 5.
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Migration activities
Taking into account the aforementioned results, the activities envisaged for migration are described
Once the migration of major public and private sector entities is successfully completed, PSPs should
enhance their communication/marketing efforts towards consumers in general, notably through their
business networks.
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Lessons from the social security migration process
In 2010 the Portuguese social security system declared its intention to adapt to SEPA requirements. It then
started a preparation process for migrating its payment orders, namely pensions and other social benefits.
In this context, and in close association with the national banking community, the social security bodies
mapped out what was needed for adaptation, with a view to using the SEPA credit transfer format
in their payments.
Lessons may be drawn from this migration process, which involves one of the main credit transfer
senders in the country. These lessons may contribute to similar preparation processes (ongoing or to be
initiated by other entities):
• It is important to have an adequate estimate of the time needed to develop IT solutions that are
compatible with the use of the ISO20022 XML standard, as well as the respective cost and resource
allocation, taking into consideration the impact on legacy credit transfer solutions used in Portugal.
• It is essential to anticipate the transaction volumes in question, both for those originating and
those processing or receiving the transactions. This is particularly important when the intention is
to have full processing on the same day (e.g. for pension payments). In the case of social security,
a considerable number of stress tests and interbank tests were needed in order to obtain a
satisfactory degree of response to ensure a minimum service level equal to that existing before
migration to SEPA. In addition, IT solutions in receiving banks did not have enough capacity to
process a very substantial volume of SEPA credit transfers (compared with the previous daily average),
which led to delays in the launch. The introduction of six additional clearing cycles for the SEPA
credit transfer subsystem helped the pension migration process.
• The return mechanisms to be used must be studied in a timely manner.
The migration process of pension payments to SEPA format was launched on 9 March 2012, when
pensioners were paid through SEPA credit transfers. The remaining social benefits (e.g. unemployment
benefits) started being paid through SEPA credit transfers in July 2012.
5.1.2 Payment service users
This Regulation affects not only PSPs, but also PSUs – small, medium-sized and large enterprises and
public administrations. These users must therefore analyse the impact of the Regulation on their operating
models without underestimating the necessary adaptation effort.
In the context of the previously mentioned cascade approach, larger entities from both the public and
the private sector must be forerunners in the migration to SEPA credit transfers and direct debits, actively
participating in migration pilots promoted by PSPs.
5.1.3 Banco de Portugal
Banco de Portugal will take the following actions:
• Development of a public information campaign on SEPA – adding to the periodical publication
of the SEPA.pt newsletter, the revision of its website contents, the distribution of the ‘SEPA: o
que é’ leaflet (‘What is SEPA’ leaflet), the release of a Banco de Portugal Booklet on SEPA and the
organisation of SEPA information events or conferences;
• Analysis and formal proposal on implementation measures, rules on penalties and aspects liable
to lead to a temporary derogation from Regulation (EU) No 260/2012 with a national impact;
• Functional readjustment of SEPA credit transfer and direct debit schemes in view of Regulation
(EU) No 260/2012 and the advantage of incorporating a number of relevant functionalities that are
currently only present in legacy schemes;
• Phasing-out of legacy credit transfer and direct debit schemes after the migration date.
In addition, Banco de Portugal will also be responsible for the cross-cutting monitoring of migration
to SEPA, following developments in migration indicators and the implementation of the activities
envisaged in this Plan (see Chapter 6 – Plan Monitoring). The Bank will also be responsible for updating
the National Migration Plan, including additional activities or further details on envisaged activities.
5.1.4 Representative associations
Consumers will make the final migration effort, as they may only migrate when all other stakeholders
are ready (PSPs and public and private sector entities). Following a campaign to be organised by Banco
de Portugal, consumer associations should provide their members with all relevant information on
SEPA credit transfers and direct debits for end users. All other associations of interest should undertake
a similar communication effort.
It is crucial that all stakeholders, and particularly consumers, are properly informed, in a timely manner,
so that they are fully prepared for the changes brought about by SEPA. In addition to Banco de Portugal,
PSPs and associations of interest should carry out specific information campaigns, in order to raise
awareness and prepare citizens for SEPA migration. In particular, citizens are required to migrate from
BBAN to IBAN as their bank account identifier.
5.2 Payment instrument perspective
In practice, migration to SEPA implies changing from legacy credit transfers and direct debits to SEPA
credit transfers and direct debits respectively.
The types of activities carried out to encourage SEPA migration should be different for credit transfers and direct debits. First, businesses using credit transfers have different characteristics and needs
from businesses using direct debits, second, SEPA credit transfers are simpler and have been available
for longer than SEPA direct debits.
7 Examples of this provision of information were the interbank meeting of 27 June 2012 and the meeting of the Payment Systems Forum’s
Steering Committee dedicated to SEPA of 5 July 2012.
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Migration activities
• Provision of information to PSPs, businesses and public administrations and interest groups; 7
5.2.1 Credit transfers
Credit transfers are transmitted: (i) bundled together by main corporate users; or (ii) individually at PSP
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branches and through remote channels (e.g. internet/Homebanking/Telebanking).
Transfers transmitted bundled together by main corporate users should be the first type of transfer
to migrate to the SEPA format, using the previously mentioned cascade approach.
In order for transfers transmitted individually at PSP branches or through remote channels (internet/
Homebanking/Telebanking) to migrate to the SEPA format, PSPs must only direct them to the SEPA
clearing subsystem. However, in order to do so, PSPs must provide all the information requested by the
SEPA scheme: the payer’s name and/or the IBAN of the payer’s payment account; the amount of the
credit transfer; the IBAN of the payee’s payment account; where available, the payee’s name and any
remittance information.
In addition, for (national or cross-border) transfers transmitted via the internet, PSPs may find it useful
to prioritise the option among their customers of carrying out SEPA credit transfers in their banking
portal, in order to increase SEPA awareness among users. For this purpose, Banco de Portugal will issue
a recommendation/best practice through a circular-letter.
The possibility of an automatic migration to the SEPA format by simply changing the bank account
identifier from BBAN to IBAN should be analysed for national transfers and standing orders.
In addition to the basic transfer service, the current credit transfer scheme has a set of Additional Optional
Services (AOSs), whose migration should be considered and scheduled in a timely manner. The migration
of some of these AOSs is essential for maintaining the level of service provided to users. The work to
define the AOSs (to be implemented in the SEPA credit transfer scheme) and establish the timeline of the
related testing and launch must take place within the scope of the Interbank Working Group on credit
transfers and will be reflected in the respective Operating Manual in due course.
5.2.2 Direct debits
Migration to SEPA direct debits should take place in accordance with an agreement between the PSPs
and the various creditors, given that Regulation (EU) No 260/2012 has established that “a valid payee
authorisation to collect recurring direct debits in a legacy scheme prior to 1 February 2014 shall continue
to remain valid after that date” (see Article 7). Migrating to SEPA direct debits implies migrating these
authorisations from the current direct debit scheme to the SEPA scheme, i.e. an authorisation migrates
to SEPA direct debits when the first direct debit in SEPA format is carried out.
Direct debits bundled together by main creditors should be the first to migrate, following the same
process as envisaged for credit transfers (by means of a cascade approach).
However, the Regulation adds to the functions currently available in the national direct debit scheme
a set of requirements to be complied with by the PSPs up to the migration end-date. For example, the
Regulation establishes that consumers must have the right to instruct their PSP: (i) to limit a collection
to a certain amount and/or periodicity; and (ii) to block any direct debits to the payment account or to
block any direct debits initiated by one or more specified payees or to authorise direct debits only initiated
by one or more specified payees (see Article 5(3)(d)). This provision requires a considerable effort by
PSPs to comply with the new requirements. Discussions on these additional requirements have been
ongoing within the Interbank Working Group on direct debits and the solutions to be implemented will
be made available to the rest of the banking community in due course.
5.3 Integrated perspective
The tables below provide lists and timelines for the migration activities described above.
Payment Service Providers
Q1
Q2
Q3
Preparation of a ‘migration guide’ to support
public and private sector entities
2013
Q4
Q1
Q2
Q3
2014
Q4
Jan.
Oct.
Compliance with necessary technical and
business requirements:
SEPA credit transfers
- Initiation through the channels of
individuals and businesses (branches and
Homebanking)
Nov.
- Implementation of AOSs
SEPA direct debits
- Implementation of checking obligations
Support to the migration of large public and
private sector entities (pilots)
Communication/information to staff in the
business network
Communication/information to customers/
consumers (small users)
SEPA credit transfers
SEPA direct debits
Promotion of migration of customers/
consumers (small users) in general
2012
Public administrations
1.º T
2.º T
3.º T
2013
4.º T
1.º T
2.º T
3.º T
2014
4.º T
Jan.
Analysis of the Regulation’s impact on their
Participation in migration pilots with PSP
support
2012
Associations of interest
Communication campaign for members
1.º T
2.º T
3.º T
2013
4.º T
1.º T
2.º T
3.º T
2014
4.º T
Jan.
15
Migration activities
2012
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2012
Banco de Portugal
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Q1
Q2
Q3
Issuing of a circular-letter to the PSPs,
recommending the option to carry out SEPA
credit transfers by default through the various
channels (branches and homebanking)
2013
Q4
Q1
Q2
Q3
2014
Q4
Jan.
Nov.
Provision of information to PSPs, businesses
and public administrations and interest
groups (interbank and bilateral meetings and
meetings of the Payment Systems Forum)
Public information campaign on SEPA:
Revision of SEPA contents at the website
of Banco de Portugal
Periodical publication of the SEPA.pt
newsletter
Jan.
Jul.
Jan.
Jul.
Jan.
Jul.
Distribution of the 'SEPA: O que é' leaflet
('What is SEPA' leaflet)
Release of a Banco de Portugal Booklet
on SEPA
Organisation of SEPA information events
or conferences
Analysis and formal proposal on optional
features (waivers) of the Regulation
Functional readjustment of SEPA Credit
Transfer and Direct Debit subsystems:
Mar.
SEPA Credit Transfers: AOSs
SEPA Direct Debits: Checking obligations
Monitorisation of SEPA migration and
supervising implementation of the National
Migration Plan
Phasing out of legacy credit transfer and
direct debit schemes
5.4 Migration goals
Taking into account the current utilisation rates of SEPA payment instruments and the need to ensure
a timely, gradual and efficient migration to SEPA credit transfers and direct debits in Portugal up to
1 February 2014, the following interim migration goals are established:
Credit transfers
Direct debits
• 40% up to the end of December 2012;
• 3% up to the end of December 2012;
• 60% up to the end of March 2013;
• 10% up to the end of March 2013;
• 80% up to the end of June 2013;
• 30% up to the end of June 2013;
• 95% up to the end of December 2013;
• 60% up to the end of October 2013;
• 100% up to the end of January 2014.
• 90% up to the end of December 2013;
• 100% up to the end of January 2014.
VI. PLAN MONITORING
1st level: Banco de Portugal
At the first level, Banco de Portugal regularly monitors the National Migration Plan, ongoing migration
activities and/or activities carried out by relevant stakeholders.
For a quantitative assessment and to ensure compliance with established migration objectives, Banco de
Portugal will compile the following set of migration indicators on a monthly basis:
Credit transfers
• Number of SEPA credit transfers processed in SICOI compared with total credit transfers processed
in SICOI;
Direct debits
• Number of SEPA direct debits processed in SICOI compared with total direct debits processed in SICOI;
• Number of direct debit authorisations in SEPA format compared with total direct debit authorisations;
• Number of creditors issuing direct debit instructions in SEPA format compared with total creditors
issuing direct debit instructions.
In parallel, for a qualitative assessment, Banco de Portugal will monitor developments in pilots and other
specific migration activities to be organised by PSPs. In this regard, the Bank will require PSPs to send
quarterly reports on these activities.
2nd level: SEPA Migration Monitoring Committee
This Monitoring Committee, comprising elements from the task force responsible for preparing this
document and chaired by Banco de Portugal, will meet at least on a quarterly basis.
On the basis of information collected by Banco de Portugal (at the 1st level), this Committee will be
responsible for:
• Assessing ongoing activities and/or activities that have been carried out, in particular migration pilots;
• Analysing developments in quantitative SEPA migration indicators and the deviation from
established objectives;
• Sharing knowledge of national and international experiences in SEPA migration;
• Proposing to Banco de Portugal the issuance of recommendations to PSPs and large users of these
services with significant delays in their respective migration process;
• Preparing a biannual report on the monitoring of SEPA migration to submit to the Payment Systems
Interbank Commission and to the Board of Directors of Banco de Portugal.
VI
17
Plan monitoring
The implementation of the National Migration Plan will be monitored at two levels.
ANNEX 1 | COMPOSITION OF THE PAYMENT SYSTEMS FORUM
In addition to Banco de Portugal, which chairs the Payment Systems Forum, the entities comprising
it and its Steering Committe dedicated to SEPA are:
BANCO DE PORTUGAL | NATIONAL SEPA MIGRATION PLAN
18
• Financial institutions and the entity managing the payments system infrastructure
–
Associação Portuguesa de Bancos (APB – Portuguese Banking Association)
–
Associação das Instituições de Crédito Especializado (ASFAC – Association of Specialised
Credit Institutions)
–
two banks participating in the Portuguese Payment Systems Interbank Commission
(currently Caixa Geral de Depósitos and Millennium BCP)
–
Interbank Services Company (SIBS)
• Consumer protection associations:
–
Associação Portuguesa para a Defesa do Consumidor (DECO – Portuguese Association for
Consumer Protection)
–
Associação Portuguesa dos Utilizadores e Consumidores de Serviços e Produtos Financeiros
(SEFIN – Portuguese Association of Users and Consumers of Financial Services and Products)
• Public administration bodies:
–
Central government: Direcção-Geral do Consumidor (Consumer Directorate General); Direcção-Geral dos Impostos (Directorate General for Taxation); Instituto de Gestão da Tesouraria e do
Crédito Público (Portuguese Treasury and Debt Management Agency); Direcção-Geral de Protecção
Social aos Funcionários e Agentes da Administração Pública (ADSE – Portuguese Directorate
General for Social Protection for Civil Servants and Contractual Staff)
–
Local government: Associação Nacional de Municípios Portugueses (National Association
of Portuguese Municipalities)
–
Social security: Caixa Geral de Aposentações (Portuguese civil servants' retirement and survivor
pensions fund); Instituto de Gestão Financeira da Segurança Social (Social Security Financial
Management Institute); Instituto de Segurança Social (Social Security Institute)
• Business sector:
–
Águas de Portugal
–
EDP - Energias de Portugal
–
Fidelidade Mundial (insurance company)
–
Jerónimo Martins (retail group)
–
PT Comunicações
–
Sonaecom SGPS
–
Sonae Distribuição SGPS (retail group)
–
TMN
–
Vodafone Portugal
–
ZON Multimédia
ANNEX 2 | QUESTIONNAIRES
8
PAYMENT SERVICE PROVIDERS (PSPS)
19
Annex
Information on the Payment Service Provider
A.1 Payment service provider
Name:
Legal person identification number:
A.2 Contacts for questions
Name:
Position:
Telephone:
Email:
Knowledge of SEPA
B.1 Are you aware of the publication of Regulation No 260/2012 of the European Parliament and of
the Council of 14 March 2012, establishing technical and business requirements for credit transfers
and direct debits in euro?8
Yes
No
B.2 Are you aware of the technical and business requirements established therein?
End-date for migration to SEPA instruments
Yes
No
Mandatory use of the XML format for communication between PSPs
Yes
No
Mandatory use of IBAN (instead of BBAN)
Yes
No
Yes
No
B.3 Do you consider the information you have on SEPA to be sufficient?
Phase of migration to SEPA payment instruments
C.1 In what phase is the internal implementation process for processing SEPA payment instruments?
Credit
transfers
Direct
debits
Not yet started
Under implementation
Completed
C.2 If the process has not yet started or is under implementation, please indicate the expected
end-date for completion
Credit
transfers
Direct
debits
2nd quarter of 2012
3rd quarter of 2012
cont. 
8 Amending Regulation (EC) No 924/2009
cont. 
4th quarter of 2012
1st quarter of 2013
20
3rd quarter of 2013
BANCO DE PORTUGAL | NATIONAL SEPA MIGRATION PLAN
2nd quarter of 2013
4th quarter of 2013
January 2014
C.3 Does this process include both sending and receiving?
Yes
No, only receiving
C.4 Do you already provide a SEPA payment option to your customers (in addition to the legacy transfer
or direct debit instrument)?
Credit transfers
Direct debits
Yes
Yes
Via Homebanking
No
When do you intend to?
No
_____________________
When do you intend to?
_____________________
At branches
Yes
Yes
No
When do you intend to?
No
_____________________
When do you intend to?
_____________________
Bundled together
Yes
Yes
No
When do you intend to?
No
_____________________
When do you intend to?
_____________________
C.5 If yes, do you provide the SEPA payment options by default?
Yes
No
When do you intend to? __________
SEPA communication for customers
D.1 Have you carried out any SEPA communication activities for your customers?
Individual activities for large customers
Yes
Please
specify
Distribution of leaflets (digital/paper)
Other. Please specify: ______________________________
No
Do you intend to?
Yes
When ? _________
No
D.2 If yes, how receptive have customers been and what types of difficulties have they reported?
_______________________________________________________________________________
Other
E.1 Do you have any suggestions to step up the migration process?
_______________________________________________________________________________
_______________________________________________________________________________
PAYMENT SERVICE USERS
Information on the Payment Service User
A.1 Organisation
21
Annex
Name:
Legal person identification number:
A.2 Contacts for questions
Name:
Position:
Telephone:
Email:
A.3 Does the organisation have any international activities (abroad and/or with foreign partners)?
Yes
No
A.4 What was the relative share of international activities in the organisation’s total activity in 2011?
Europe
Outside Europe
Non-existent
Less than 1%
From 1% to 10%
From 10% to 25%
From 25% to 50%
More than 50%
A.5 Do these international activities correspond to exports and/or imports (i.e. do they involve receiving
and/or submitting international payments)?
Yes
No
Knowledge of SEPA
B.1 Has the single euro payments area (SEPA) already been mentioned within the organisation?
Yes
No
B.2 How did you become aware of the project to create the single euro payments area (SEPA)?
Banco de Portugal
Commercial bank/your bank
Government
IT services provider
Other
Please specify: ____
B.3 Do you consider the organisation’s information on SEPA to be sufficient?
Yes
No
cont. 
cont. 
B.4 Are you aware of a customer-to-bank communication manual (C2B), adopted by the national
banking community, enabling the use of the same file format to carry out transfers and direct
debits through banks operating in Portugal?
BANCO DE PORTUGAL | NATIONAL SEPA MIGRATION PLAN
22
Yes
No
B.5 Are you aware of the publication of Regulation (EU) No 260/2012 of the European Parliament
and of the Council of 14 March 2012 establishing technical and business requirements for credit
transfers and direct debits in euro9?
Yes
No
B.6 Are you aware of the technical and business requirements established therein?
End-date for migration to SEPA instruments
Yes
No
Mandatory use of the XML format when sending instructions/files to PSPs10 Yes
No
Mandatory use of IBAN (instead of BBAN)
No
Yes
Phase of migration to SEPA payment instruments
C.1 What is the current phase of preparation for migration of
payment instruments to SEPA format?
Credit
transfers
Direct
debits
Credit
transfers
Direct
debits
Credit
transfers
Direct
debits
We have not yet started the impact analysis
Under analysis and/or definition of strategies
Under implementation
We already use SEPA instruments together with legacy instruments
We only use SEPA instruments
C.2 If you answered “We have not yet started the impact analysis”,
please indicate the reason why:
We were not aware of the need for any changes
We were waiting for migration to be mandatory (setting of an end-date)
We were waiting for our bank to take the initiative
Other. Please specify: __________________________________________
C.3 If you answered “We already use SEPA instruments together
with legacy instruments”, indicate the reason why you haven’t
fully migrated to SEPA:
Not all banks were ready to receive transactions using SEPA payment
instruments
Your bank advised you to carry out a step-by-step migration
Other. Please specify: ___________________________________________
cont. 
9 10
9 Amending Regulation (EC) No 924/2009.
10 Payment Service Providers.
cont. 
C.4 If you answered “Under implementation” or “We already use
SEPA instruments together with legacy instruments”, please
Credit
transfers
Direct
debits
indicate, taking into account the SEPA migration end-date
23
Annex
(1 February 2014), the date when your organisation plans to
migrate or complete its migration to SEPA payment instruments:
2nd quarter of 2012
3nd quarter of 2012
4nd quarter of 2012
1nd quarter of 2013
2nd quarter of 2013
3nd quarter of 2013
4nd quarter of 2013
January 2014
C.5 If you answered “We only use SEPA instruments”,
please indicate:
Credit
transfers
Direct
debits
Credit
transfers
Direct
debits
C.5.1 Difficulties faced
Not all banks were ready to receive transactions using SEPA payment
instruments
Other, Please specify: _____________________________________
C.5.2 Time needed to implement the project:
Less than 3 months
From 3 to 6 months
From 6 to 9 months
From 9 to 12 months
More than 12 months
C.6 The migration project to SEPA instruments will be
implemented through
In-house development
Outsourced development (software house)
Other. Please specify: _________________________________________
SOFTWARE SUPPLIERS
Software supplier information
BANCO DE PORTUGAL | NATIONAL SEPA MIGRATION PLAN
24
A.1 Organisation
Name:
Legal person identification:
A.2 Contacts for questions
Name:
Position:
Telephone:
Email:
Knowledge of SEPA
B.1 Has the single euro payments area (SEPA) already been mentioned within the organisation?
Yes
No
B.2 How did you become aware of the project to create the single euro payments area (SEPA)?
Banco de Portugal
Commercial bank
Government
Customer
IT services provider
Other
Please specify: _______
B.3 Do you consider the organisation’s information on SEPA to be sufficient?
Yes
No
B.4 Are you aware of a customer-to-bank communication manual (C2B) adopted by the national
banking community, enabling the use of the same file format to carry out transfers and direct
debits through banks operating in Portugal?
Yes
No
B.5 Are you aware of the publication of Regulation (EU) No 260/2012 of the European Parliament
and of the Council of 14 March 2012 establishing technical and business requirements for credit
transfers and direct debits in euro11?
Yes
No
B.6 Are you aware of the technical and business requirements established therein?
End-date for migration to SEPA instruments
Yes
No
Mandatory use of the XML format for communication with PSPs
Yes
No
Mandatory use of IBAN (instead of BBAN)
Yes
No
cont. 
11
11 Amending Regulation (EC) No 924/2009
cont. 
Phase of migration to SEPA payment instruments
C.1 Do you offer SEPA products/services among your solutions?
25
Annex
We have not developed any solution
We are analysing possible solutions
We are developing solutions
We have developed solutions but the overall offering is still incomplete
Please specify when you expect
to market your solutions:
Credit transfers
Direct debits
2nd quarter of 2012
3nd quarter of 2012
4nd quarter of 2012
1nd quarter of 2013
2nd quarter of 2013
3nd quarter of 2013
4nd quarter of 2013
Our solution is already being marketed
Since when? ________________________________________________________________
Which activity sectors does it target? ___________________________________________
How receptive have customers been and what types of difficulties have they repoted?
______________________________________________________________________________
Other
Please specify _______________________________________________________________
C.2 How long do you think you need to implement your commercial
solution to process SEPA payment instruments?:
Credit
transfers
Direct
debits
Less than 3 months
From 3 to 6 months
From 6 to 9 months
From 9 to 12 months
More than 12 months
Other
D.1 Do you have any suggestions to step up the migration process?
_______________________________________________________________________________
_______________________________________________________________________________
ANNEX 3 | ANALYSIS OF RESPONSES TO THE QUESTIONNAIRES
Payment service providers (PSPs)
BANCO DE PORTUGAL | NATIONAL SEPA MIGRATION PLAN
26
The objective of the questionnaire sent to PSPs was to assess the degree of knowledge of SEPA, their
migration phase and the communication activities carried out for their customers.
This questionnaire was sent to the 52 participants in the legacy schemes under SICOI’s credit transfer and
direct debit clearing subsystems. 32 responses were received, i.e. a response rate of 61.5%.
1. Knowledge of SEPA
All PSPs that responded to the questionnaire said they were aware of the publication of Regulation
(EU) No 260/2012 and the business and technical requirements established therein, specifically the
mandatory end-date for migration to SEPA instruments, the mandatory use of IBAN instead of BBAN and
the mandatory use of the ISO20022 XML standard for communication between PSPs. One respondent
considered the information available on this last requirement to be insufficient.
2. Phase of migration to SEPA payment instruments
Of the PSPs that responded to the questionnaire, 62.5% indicated their internal process to implement
the processing of SEPA credit transfers was complete, while for 34.4% the process is still under
implementation. Of the latter, 11.1%, 44.4% and 44.4% reported they intend to complete the
implementation process during 2012, 2013 and only in January 2014 respectively. As regards the
channels provided to receive transfer orders from their customers (individuals and businesses), 46.9% of
respondents have provided a payment option by SEPA transfer via Homebanking, 68.8% at branches and
43.8% bundled together. PSPs that have yet to provide the option of carrying out SEPA credit transfers
through these channels have generally pointed to 2013 as the expected implementation date.
In turn, 6.3% of respondents have not yet started the work needed to implement SEPA direct debits,
37.5% reported the process was under implementation, while 31.3% have completed it. Of the PSPs
that have not yet started the implementation or whose process is under implementation, 28.6% expect
the work to be completed only in January 2014, 50% during 2013 (in particular in the first and third
quarters) and 21.4% by the end of 2012. Only 25% of respondents provide customers with a payment
option by SEPA direct debit via Homebanking, 31.3% at branches and 28.1% bundled together. Most
PSPs that do not provide these channels to their customers intend to do so in 2013. However, some
of the PSPs pointed to 2014 as their expected date or did not give any date.
78.1% of respondents reported that the solution they are implementing in-house includes sending
and receiving payment transactions, while 9.4% intend to only develop the receiving component.
Finally, only 21.9% of respondents provide SEPA payment instruments by default to their customers.
3. SEPA communication for customers
Of the PSPs that responded to the questionnaire, 45.2% have already carried out at least one
communication activity for their customers. The main reported activities are the following: individual
contacts with large customers (44%), distribution of digital/paper leaflets (24%) and other initiatives
(32%) such as SEPA information on the institutional website, publication of pricelists, release of the new
offer through business areas and direct information activities for some customers.
Customers have been very receptive to PSPs’ activities and cite the costs/investment needed to migrate
and the proximity of the migration end-date as their main difficulties. In particular, customers reported:
(i) a lack of sensitivity to migration end-dates; (ii) the costs and complexity of migrating to the new SEPA
formats (collection of customers’ BICs and IBANs); (iii) expectation that PSPs will provide format migration
SEPA credit transfers (e.g. salary processing and fund provision); (v) dependence on external decisions
(parent company); (vi) dependence on developments by software suppliers to integrate invoicing and
collection systems; (vii) perception that SEPA credit transfers are not yet stabilised; (viii) no ‘Debtor Mandate
Flow’ component (specifically to activate and manage a direct debit authorisation through Multibanco);
and (ix) strict deadlines to send a direct debit FIRST collection (D-14 to D-5). By contrast, 54.8% of
respondents have yet to launch any communication activity. Of these, 76.5% intend to do so at different
timelines up to January 2014, while 23.5% are not planning any initiative on SEPA.
4. Other
Respondents made the following suggestions to step up the SEPA migration process in Portugal:
• Define and release migration end-dates at a national level;
• Carry out information activities on the advantages of SEPA (e.g. promote the use of IBAN) in the media;
• Organise briefing and training sessions on SEPA migration;
• Publish newsletters;
• Draw up a uniform and credible communication plan to be released by Banco de Portugal;
• Promote cooperative solutions to minimise the impact on corporates of adapting to SEPA;
• Create SEPA migration guides with supporting documentation to ensure stakeholders migrate
to the new formats in a timely manner;
• Carry out activities to raise awareness among software suppliers of the need to provide their systems
with a default C2B format compatible with SEPA;
• Define a consensual and common migration timeline.
Payment service users
The payment service user questionnaire was aimed at corporates and public administrations represented
in the Payment Systems Forum in order to collect information from the main credit transfer issuers and
direct debit payers in Portugal. The objective of the questionnaire was to obtain information on the
type of activity carried out by the users, the degree of knowledge of SEPA and the status of preparation
for SEPA migration.
The questionnaire was sent to a sample of 16 entities, with a response rate of 62.5% (10 complete
responses).
1. Information on the payment service user
90% of the payment service users that responded to the questionnaire reported having international
activities. European activities have a share of more than 50% for only 10% of these users, from 10%
to 25% for 20% of users and less than 10% for the remaining users. By contrast, activities outside Europe
account for less than 10% of total activity for 60% of users and from 25% to 50% for 20% of users.
According to the responses provided, for 70% of users international activities correspond to exports
and/or imports of goods or services (which imply receiving and/or submitting international payments).
27
Annex
services, with no impact on customers; (iv) difference in treatment between legacy credit transfers and
2. Knowledge of SEPA
90% of respondents reported they had already mentioned the subject of SEPA within their
organisation. Of these, 53.8% reported they became aware of the SEPA project through Banco de
Portugal and 38.5% through their PSP.
BANCO DE PORTUGAL | NATIONAL SEPA MIGRATION PLAN
28
Around 90% of respondents claimed they were familiar with the customer-to-bank (C2B) communication
manual and Regulation (EU) No 260/2012 and were particularly aware of: (i) the end-date for migration
to SEPA; (ii) the mandatory use of the ISO20022 XML format when transmitting files bundled together
to PSPs; and (iii) the mandatory use of IBAN (instead of BBAN). Only 20% of respondents consider the
information they have on SEPA to be insufficient.
Finally, the sample defined by Banco de Portugal only includes the main credit transfer initiators and
direct debit collectors in Portugal. The questionnaire was not sent to SMEs. In this respect, SMEs are
expected to have substantially less information and knowledge of SEPA.
3. Status of migration to SEPA payment instruments
As for the phase of preparation for migration to SEPA credit transfers, 20% of respondents reported
they had not yet started the impact analysis (due to the fact that they were not aware of the need for
changes or were waiting for their PSP to take the initiative), 30% had started the impact analysis and/or
were defining their strategies and for 10% the process is currently under implementation. Of the latter
(those whose process is currently under implementation or who are already using SEPA transfers together
with legacy transfers), 80% intend to complete their migration process still in 2012.
The remaining 50% said they use SEPA credit transfers and legacy credit transfers simultaneously, citing
lack of preparation by the PSPs to receive transactions in SEPA format (66.7%) or technical reasons (33.3%)
for not fully migrating to SEPA. Entities that have already migrated their transfers to SEPA reported that
the project implementation period exceeded six months.
Migration to SEPA credit transfers will be developed in-house for 50% of respondents, exclusively via
outsourcing (software suppliers) for 33.3% and both in-house and via outsourcing for 16.7%.
In relation to migration to SEPA direct debits, 20% of respondents reported they had not yet started
the impact analysis, 40% had started the impact analysis and/or were defining their strategies, for 20%
the process is under implementation and the remaining 20% already use SEPA direct debits together with
legacy direct debits. The latter mentioned that the migration process to direct debits is not complete due
to the fact that not all banks are ready to receive transactions in SEPA format and they require further
IT developments.
Of the entities that have not yet started their impact analysis, 66.6% reported that they are waiting
for their PSP to take the initiative or provide the service.
Of the entities that are implementing SEPA direct debits or that, having completed their implementation,
are still using legacy instruments simultaneously, 60% intend to complete the migration process during
2012 and 40% between the second and third quarters of 2013.
The sole entity that uses SEPA direct debits reported that the implementation process took nine to
12 months.
Adaptation to SEPA will be developed exclusively in-house for 42.9% of respondents, via outsourcing
for 28.6% and both in-house and via outsourcing for the remaining 28.6%.
Software Suppliers
The questionnaire sent to Software Suppliers assessed the degree of knowledge and preparation to
cooperate with their customers in the migration to SEPA (specifically in offering solutions compatible
with SEPA).
(i.e. a response rate of 66.7%)
1. Knowledge of SEPA
All software suppliers that responded to the questionnaire reported that they were aware of the SEPA
project. They became aware of the project through: Banco de Portugal (22.2%), commercial banks
(22.2%), customers (16.7%) and other sources, such as the media, internet and contacts with their
international units (33.3%).
80% of respondents considered their organisations had sufficient available information and claimed
to be aware of the customer-to-bank (C2B) communication manual, adopted by the national banking
community, as well as Regulation (EU) No 260/2012 and its main technical and business requirements.
2. Status of migration to SEPA payment instruments
Regarding the availability/offering of SEPA solutions, 40% of suppliers that responded to the questionnaire
reported that they already offer products in this domain, 10% are still analysing possible solutions (and
expect to begin marketing solutions for credit transfers and direct debits in the first quarter of 2013),
10% are currently developing solutions (and expect to begin marketing their products in the second
quarter of 2013); and another 10% have developed solutions although the overall offering is incomplete.
30% of respondents considered that none of the previous responses apply to their situation, reporting
that they provide solutions tailored to their customers’ needs.
The time cited as needed to implement the SEPA payment instruments varies significantly between
responses. For SEPA credit transfers, 40% of respondents consider they need a period of less than three
months, 10% between three and six months, 10% between six and nine months and 20% between
nine and 12 months. For SEPA direct debits, 10% of respondents reported a period of less than three
months, 10% between three and six months, 10% between nine and 12 months, while 70% don’t
know/don’t answer.
These software suppliers cited the process of implementing SEPA in their accounting systems as the main
difficulty reported by their customers.
Annex
29
The questionnaire was sent to 15 software suppliers, of which 10 responded
3. Other
The respondents to the questionnaire gave the following suggestions to step up the SEPA migration process:
• Foster the establishment of working groups with the suppliers of IT system products/services, in order
to increase their knowledge and enhance their responsiveness to the needs of other stakeholders.
BANCO DE PORTUGAL | NATIONAL SEPA MIGRATION PLAN
30
• Promote the creation of a dedicated website for the adoption of SEPA instruments in Portugal with
all the relevant information, broken down by organisation type (software suppliers, banks, small
and medium-sized enterprises, etc.).
• Disseminate information on the advantages and benefits of adopting SEPA instruments for
stakeholders through communication campaigns for associations and entities representing the
various sectors involved.
• Outline a ‘General Guidance Programme’ with activities to integrate domestic schemes into SEPA
schemes and implement a governance structure that monitors these activities and ensures they are
carried out.
• Define pricing policies that foster migration to SEPA.
• Establish proactive measures on the part of the PSPs to anticipate migration to SEPA of customers
and volume
ANNEX 4 | 50 LARGEST CREDIT TRANSFER PAYERS
Adecco RH
Payshop Portugal
31
Banco BNP Paribas Personal Finance
Pingo Doce
Annex
(in alphabetical order)
Banco Comercial Português
Portugal Telecom SGPS
Banco Credibom
Prosegur - Segurança
C.M. Lisboa
Randstad RH - Trabalho Temporário
Centro Segurança Social Madeira
RTP
Charon - Serviços de Segurança e Vigilância
Santa Casa da Misericórdia de Lisboa
Chronopost Portugal - Transporte Expresso
Santander Totta - Seguros de Vida
Internacional
Combined Insurance Company Europe
Companhia de Seguros Allianz Portugal
CP - Comboios de Portugal
CPH RH
CTT
Dia Portugal - Supermercados
Eurest (Portugal) - Soc. Europeia de Restaurantes
Fidelidade Mundial e Império Bonança - Seguros
Franquiger - Loja do Condomínio
Generali (Sucursal Portugal) - Seguros
IGAPHE - IAJ (Inst. Gest. e Alienação do Patr. Hab.
do Estado)
IGCP
Instituto da Segurança Social
Instituto Gestão Financeira Segurança Social
ISS Facility Services
Kelly Services - Trabalho Temporário
Lusitânia - Companhia Seguros
Luso Temp - Trabalho Temporário
Médis - Seguros de Saúde
Modelo Continente Hipermercados
Ocidental - Seguros
Ocidental - Seguros Vida
Oney Instituição Financeira de Crédito
Securitas - Segurança
Sindicato Bancários Sul e Ilhas
Sindicato dos Bancários do Norte
Sindicato Nacional SAMS
Tempo Team RH - Trabalho Temporário
Tempo Team Serviços
Tranquilidade
Transportes Aéreos Portugueses
Victoria - Seguros
Volkswagen Group Services
Worten
ANNEX 5 | 30 LARGEST DIRECT DEBIT CREDITORS
(in alphabetical order)
BANCO DE PORTUGAL | NATIONAL SEPA MIGRATION PLAN
32
Allianz
American Life Insurance Company
AXA Seguros
Banco BNP Paribas Personal Finance
Banco Credibom
Banco Primus
Banco Santander Consumer PT
Cabovisão
Caixa Leasing e Factoring
Cetelem
EDP
Endesa Energia - Sucursal em Portugal
EPAL - Empresa Portuguesa das Águas Livres
Fidelidade Mundial
Imperio Bonança Comp. Seguros
Liberty Seguros
Lisboa Gás
Lusitaniagás
Ocidental Comp. Portuguesa Seguros
Ocidental Comp. Portuguesa Seguros Vida
Oney
PT
Santander Totta Seguros - Comp. Seguros de Vida
Securitas Direct Portugal
Sonaecom
Telepac II
TMN
Tranquilidade
Vodafone Portugal
ZON