With less than 3 months to go until the 1st August SEPA deadline, today the EPC launched a 3 month consultation period on possible changes to the SEPA Credit Transfer and SEPA Direct Debit rulebooks. This post examines the details of the announced consultation period, and offers some personal thoughts around the need of this consultation period at this moment in time.
The following links to the EPC announcement: http://www.europeanpaymentscouncil.eu/index.cfm/about-epc/epc-news/three-month-public-consultation-on-the-evolution-of-sct-and-sdd-schemes-feedback-by-15-august-2014/
Evolution of SEPA – Timeline:
19 May, 2014 – The EPC 3 month public consultation period looks to understand what changes could / should be made to the SEPA Credit Transfer (SCT) and SEPA Direct Debit (SDD) Rulebooks.
15 August, 2014 – All SEPA stakeholders should submit their feedback to the EPC
November, 2014 – The next generation rulebooks (SCT, SDD-CORE, SDD-B2B) and associated SEPA guidelines will be published
November, 2015 – The new rulebooks will go live
How Can I Submit My Feedback to the EPC?
The following links take you to the appropriate Change Request Consultation Document and Response Template, follow the links and send your feedback to the indicated email address:
- SEPA Credit Transfer – Rulebook Change Request Consultation Document and Response Template
- SEPA Direct Debit CORE – Rulebook Change Request Consultation Document and Response Template
- SEPA Direct Debit B2B – Rulebook Change Request Consultation Document and Response Template
What kind of changes might be made?
I suppose anything could potentially be changed! I didn’t realise this, but this 3 month public consultation period was announced last month, in April 2014. The link to that April 2014 announcement can be found here: http://www.europeanpaymentscouncil.eu/index.cfm/newsletter/article/?articles_uuid=5BF0439C-5056-B741-DB37E1B600B55EE1
What’s more interesting is that the article offers some examples of suggested modifications, these include:
- SDD Core standard time cycle: make current option to use a shorter time cycle for the presentation of first, recurrent and one-off direct debit payments mandatory
- SDD: simplify sequence types (OOFF, FRST, RCUR, FNAL)
- SDD: greater flexibility around the use of electronic mandates
- SCT and SDD: introduction of more than 140 characters for remittance information
Sounds great, what’s the problem?
Consider this… you’re making some banoffee pie, at what point would you consider improving the recipe ? Surely you would try it first, and then think about adding more toffee, cream, chocolate – or all of them! 🙂
I don’t disagree with the need for a public consultation. For me the main concern lies in the timing of the consultation. Right now most corporates are working to wrap up their SEPA implementations, and where these are largely complete, corporates are looking to stabilise their newly implemented SEPA processes. So in this period of both implementing and stabilising SEPA, I would question the type of feedback and suggestions the public consultation will receive. It would have been far better to have started the consultation after the August 2014 go live date. Perhaps a consultation period starting in September 2014 would have provided an opportunity for corporates to review their SEPA landscape, and based on that provide more informed feedback.
Some corporates wont have the time to provide feedback, and in fact will be thinking ‘oh no’ we’ve only just implemented SEPA and now ‘they’re’ going to change it again!
In the current climate, corporates may actually provide feedback on their SEPA implementation experience. You could argue this implementation experience will not result in ‘good’ feedback which will do little to positively improve SEPA. For an improved SEPA environment we need corporates to provide feedback that puts the implementation experience behind them, considers SEPA as the norm, and then considers how we move forward from here.