SEPA / NASO
The creation of a Single Euro Payment Area (SEPA) aims at encouraging the integration of the European market by facilitating the cross border electronic payments in euro between the countries participating in SEPA by making them cheap and secure similar to the existing national payments. In SEPA banks’ clients may order payments to beneficiaries’ accounts in banks situated in other euro area countries by using a single bank account and the same payment instruments. The SEPA project is initiated by the European Commission (EC) and the European Central Bank (ECB) with the support of the European Payment Council (EPC), which unites banks’ representatives, associations and other organizations participating in the payment process in Europe. The SEPA project practically started as of January, 28th, 2008 when the banks participating in the project began to perform SEPA Credit Transfers (SCT).
As of the beginning of 2016 the ABB changed its membership in the EPC from full membership to associated membership. Due to its new statute the ABB does not have a representative in the EPC General Assembly but it kept its representative in the Scheme Evolution and Maintenance Working Group /former SEPA Payment Schemes Working Group/. The ABB has also a representative in the Payment Systems Committee at the European Banking Federation /EBF/ where the ABB is a full member and thus it also follows the EPC activities. A lot of information on SEPA instruments, standards and infrastructures for payments and procedures for banks’ adherence to SEPA is published on the Internet sites of ECB, EPC and EBF.
As of the beginning of September 2007 the EPC started procedure for adherence of banks that are ready to perform SEPA credit transfers (SCT) as of the 28th of January 2008 as the EPC prepares and maintains an updated register of these banks. All the Bulgarian banks are included in the Register of participants maintained by the EPC about the banks that perform SEPA credit transfers. Since November 2009 the SEPA direct debit scheme has started and it has been established in two varieties – Core SDD scheme and B2B SDD scheme. Only one bank from the country is included in the Register of Particpants of the banks performing B2B SDD. SEPA direct debits are not a popular instrument in Bulgaria, consumers do not have any interest to them and for that reason they are not developed by the banks in the country. As of March, 2012 Regulation 260/2012 establishing technical and business requirements for credit transfers and direct debits in euro, which defines the end date for migration to SEPA. The euro area member-states migrated to SEPA up to August 2014 and the deadline for migration for the member states, outside the euro area as Bulgaria was 31st of October 2016.
As of 21st of November 2017 instant SEPA credit transfer scheme /Inst. SCT/ was initiated. This is an optional SEPA scheme as B2B SDD. These transfers are performed on the principle 24/7/365, i.e. they can be performed each day of the year, 24 hours during the day. The maximum amount of these transfers is 15 000 EUR and the time for transaction is 10 seconds. The EPC has taken a decision to make a review each year and when it is necessary to revise the maximum amount of those transactions as well as the time for their execution. Currently, banks in Bulgaria do not offer such transactions. In order to declare their participation in the SEPA schemes the banks should fill in the adherence pack that can be downloaded from the EPC website. The adherence pack contains Adherence Agreement, Schedule and Legal Opinion which are sent by the banks in two original copies to the National Adherence Support Organization (NASO) at the ABB.
It is mandatory the Legal Opinion to be signed by an internal or external counsel (lawyer). The date on the Legal Opinion should coincide with the date on the Adherence Agreement or to be a later date than the date on the Adherence Agreement. If the date on the Legal Opinion is earlier than the date on the Adherence Agreement the adherence pack is considered to be invalid.
NASO reviews the adherence pack for the necessary stamps and signatures and sends it to the EPC as the final decision for adherence to the SEPA scheme is taken by the Compliance and Adherence Committee at the EPC. After the initial date of 28th of January 2008 when SCT started the EPC announces on its Internet site a timeframe for the banks that are willing to adhere to the schemes.
By a decision of the Executive Board of the ABB as of October, 19th, 2007 a National Adherence Support Organization (NASO) was created at the Association. The role of NASO is to facilitate the process of banks’ adherence to SEPA by consulting them on different issues in relation to banks’ participation in the schemes and communicates with the EPC, mainly in transmitting the adherence pack to the EPC regarding the banks’ participation in the Scheme. Banks that are members of the ABB may send questions to the NASO regarding its activities and the adherence to the SEPA schemes on the following e-mail: email@example.com.
The adherence pack for the SEPA schemes as well additional information on the adherence procedures and a list of the existing NASOs in the EU member states can be found on the EPC Internet site. A Register of Participants is also published on the EPC Internet site where the banks that have joined to the SCT, SDD schemes /Core SDD and B2B SDD/ and SEPA instant credit transfers /SEPA Inst./ are included as this information is updated periodically. The deadlines for submission of the adherence documents are also published on the EPC website as well as the dates for the inclusion of the banks in the Register of participants.
Banks can submit their adherence packs for performing SEPA credit transfers (SCT), SEPA direct debits (Core SDD и B2B SDD) and instant SEPA credit transfers (Inst. SCT) in the following ways:
- Subsidiaries that participate in SEPA through the parent bank can submit the adherence pack through the local NASO, or through the NASO situated in the country in one of subsidiaries adhering to the Scheme, or through the NASO situated in the country of the parent bank. When subsidiaries submit the adherence pack simultaneously they can do this through a chosen NASO, or directly to the EPC. If the parent bank has agreed several subsidiaries, incl. the Bulgarian one, in order to submit the adherence pack together the parent bank can submit it directly to the EPC, or use some of the ways described above. The way in which the bank is going to submit its adherence pack depends on the agreement between the parent bank and the subsidiary;
- Banks that have agreed to perform SEPA transfers by joining directly to PE-ACH or through another bank, either a local or licensed in the EU bank, may submit the adherence pack through the Bulgarian NASO or through the NASO situated in the country of the agent bank, which is going to submit the documents to the EPC if the Bulgarian bank and the agent bank have agreed on this.
- Branches of banks licensed in the EU adhere to the schemes automatically if the parent bank has accomplished the respective procedures on adherence and they do not use a NASO for adherence to the scheme. Information on the e-mails of the already created NASOs in the EU member states can be reached on the EPC web site.