ON 24-Mar-2025, the European Payments Council published the verification of payee scheme adherence process that provides detailed guidelines for participants to join the VOP scheme.
The EPC expects a high number of expected adherence requests, and hence, the EPC cannot guarantee to complete the adherence requests received after 30 June 2025 to access the EDS by 5 October 2025. So, Applicants must consider submitting adherence requests asap. (Detailed in the “Three Waves of Adherence” section below).
Though, at a high level, the VOP scheme adherence documentation closely resembles the documentation of other EPC schemes, the VOP adherence includes certain nuances that the participants must be aware of. We will cover the adherence process at a high level, along with the key points specific to the VOP scheme.
Key Points to Note
Our advice to Banks & PSPs is to act immediately on this.
The EPC VOP Scheme adherence process and the paperwork is similar to other EPC schemes.
Pre-Requisites for submitting adherence requests:
- Meeting Participant Eligibility as per Section 4.4 of Rulebook
- Valid Business Identifier Code (BIC)
The 2-Phase Adherence Process
- Phase 1 – Documental Adherence: This is the fee payment and paperwork phase. This phase primarily involves the participant and EPC. RVMs can act as agents on behalf of the participants.
- Phase 2 – EDS onboarding and updating: This phase involves onboarding and configuring the EPC Directory. There is no dependency on EPC during this phase, and the tasks shall be taken care of by the RVMs that represent the participant.
The 3 Waves of Adherence Process
The EPC plans to complete the adherence process in 3 waves and has published the following timelines for the three waves:
In our opinion, as a risk mitigation effort, participants must try to be part of Wave 1 since the approval window for Wave 2 closes only on 10 Sep, which is just 25 days before the regulatory deadline. This provides adequate time for functional testing, ART conformance testing, internal approvals, and change management activities.
How to Submit the Documents?
You can submit the documents via one of the following methods:
- Self Submission
- Agents (RVMs like Banfico are authorised agents for submitting the requests)
- NASOs
Preferred mode: E-signed and by email to [email protected]
Adherence Documents that Need to be Submitted
Similar to the other schemes operated by EPC, the following documents are published:
The VOP adherence pack includes the following annexures:
- Annex H-1 Verification Of Payee Adherence Agreement (Mandatory)
- Annex H-2 Verification Of Payee Schedule (Mandatory) – Excel Version (EPC Preferred Version) or Word Version
- Annex H-3 Verification Of Payee Legal Opinion (Mandatory only for select applicants)
- Annex H-4 Standard Legal Opinions for licensed branches of non-SEPA country institutions – VOP Scheme (Mandatory only for select applicants)
Let us Connect!
Get in touch with Banfico for more information on VOP, or simply schedule a meeting by clicking on the image below.
Reference
EPC Toolkit for new VOP participants:
Banfico periodically sends newsletters on various topics related to EPC Verification of Payee implementation. Visit this page to read the previous newsletters.