VoP Opt-Out for SEPA Files: BaFin Grants Transitional Relief for EBICS Customers
The Instant Payments Regulation (IPR) initially included a directive for EBICS clients that would have caused significant issues starting in October: SEPA and instant payment files containing only a single transaction would have been required to undergo mandatory IBAN name verification without the option to opt out. As a result, these files could only have been processed through subsequent approval via VEU. Institutions and clients lacking the necessary software and process support would no longer have been able to submit such payments. European supervisory authorities have now responded by granting a transitional period – as confirmed by BaFin in its FAQs on the IPR. This provides banks and EBICS clients with valuable time to adapt their systems and processes.
Note: This blog article focuses on payment transactions for EBICS corporate clients, who are affected by this updated EU regulation.
EBICS customers can breathe a sigh of relief: Transition period for VoP single payments
The EU regulation on Verification of Payee (VoP) in conjunction with the Instant Payments Regulation (IPR) would have hit EBICS corporate customers particularly hard from October 2025: Corporate customers can optionally use VoP (opt-in) or do without it (opt-out) – but: The opt-out only applies to collectors and a collector consists of at least two transactions. It would therefore not have been possible to opt out for files with only one transaction. Treasury departments and other business areas in particular send many individual payments – so far often via the EURO express payment (EBICS order type CCU), where VoP plays no role. In future, these payments should increasingly be made cost-effectively as real-time transfers – where VoP is relevant. This is exactly where the regulation would have applied.
The intended forced VoP process for single files (opt-in)
For files with only one payment, the payer would effectively be forced into the VoP process. The process in detail:
- The bank initially stops the payment.
- It sends a VoP request to the recipient bank.
- After a few seconds, the answer is available.
- The ordering bank makes it available as a pain.002 VoP status report (can be called up via EBICS order type VPZ).
- The payer downloads the status report, checks it – and must approve the payment (again) via VEU.
Change effort on several levels
The VoP process not only means additional testing and approval steps on the customer side, but also requires VoP-capable customer software. Standard solutions can usually handle this; however, in-house developments or specially configured systems require considerable internal or external development effort.
Particularly critical: On October 2, 2025, a single payment file would still have been processed directly; from October 6, banks would have had to reject it or transfer it to the mandatory VoP. The individual banking associations want to outline different implementation paths for this in order to map the mandatory VoP for single files with a single transaction. To avoid this, workarounds have been considered:
- splitting: splitting a single payment,
- adding a “1-cent self-payment” (file then contains two payments),
- subsequent merging of individual files,
- switching to EURO express payment (CCU) – more expensive, but VoP-free.
However, all variants increase complexity, harbor sources of error and are operationally unclean.
BaFin decision: Tolerance of the opt-out for single files “until further notice”
BaFin has reacted to the practical consequences and suspended the VoP obligation for payment files with only one payment until further notice. The FAQ on the Regulation on Real-time Credit Transfers states (excerpt):
In individual cases of low payment volumes, payment service users may submit files with only one transfer order to the payment service provider. In such cases, Bafin will not raise any supervisory objections if a payment service provider offers the payer, who is not a consumer, a waiver of recipient verification even for files with only one transfer order submitted by means of remote data transmission. This waiver applies until further notice. BaFin expressly reserves the right to review the implementation and supervisory tolerance if necessary.
BaFin FAQ "Questions and answers on the regulation on real-time credit transfers" (VoP/IPR)
For now, corporate customers can make unrestricted use of the VoP opt-out – even for individual files – and the changes planned for October 6 will not apply in this case. The feared “VoP chaos” will therefore not occur.
If a corporate customer wishes to initiate the VoP check, they must ensure that the software they are using can handle VoP and the new order types. This way, nothing stands in the way of the check.
This new decision is also advantageous for banks: it reduces the amount of research and support requests from customers. Technically, and due to the short-term nature of this decision, banks have already implemented the above-mentioned rejection or conversion to mandatory VoP. The forward-looking institutions have programmed this in such a way that it can be controlled at short notice via a switch, while others have to program this regulation out.
Conclusion
With its regulatory tolerance for individual files, BaFin is providing pragmatic relief for EBICS corporate customers and banks – until further notice. This means that existing processes can be continued without mandatory VoP. At the same time, VoP remains optional, provided that software and approval processes are prepared. Banks should promptly map the toleration parametrically, communicate it transparently and document it technically – also with a view to a possible later reassessment by the supervisory authority.
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