EU Instant Payments Regulation: The 2027 Deadlines for Payment and E-Money Institutions

What the Instant Payments Regulation is

Regulation (EU) 2024/886, the Instant Payments Regulation (IPR), was adopted on 13 March 2024, published in the Official Journal on 19 March 2024 and entered into force on 8 April 2024. It amends the SEPA Regulation (Regulation (EU) No 260/2012), the cross-border payments Regulation (Regulation (EU) 2021/1230), the Settlement Finality Directive (SFD) and the second Payment Services Directive (PSD2). An instant credit transfer is a credit transfer executed immediately, 24 hours a day and on any calendar day.

The rule at its centre is simple: a payment service provider (PSP) that offers its customers euro credit transfers must also offer instant euro credit transfers, both sending and receiving. Around that rule the IPR sets price parity, verification of the payee and a new approach to sanctions screening, and it opens payment systems to non-bank PSPs.

The European Commission's implementation Q&A confirms that every payment institution (PI) and electronic money institution (EMI) offering euro credit transfers is in scope, whether or not it participates directly in a payment system, and that this includes small PIs and small EMIs. A firm that offers no standard euro credit transfers has no obligation to offer instant ones. The IPR does not apply to PIs and EMIs located outside the European Economic Area (EEA), so a UK firm is in scope only through an EU-authorised entity.

Key deadlines at a glance

The 2027 deadlines for payment and e-money institutions

Banks in the euro area have been receiving instant euro transfers since 9 January 2025 and sending them since 9 October 2025. PIs and EMIs received later dates because, until the IPR amended the SFD, they were effectively prevented from participating in designated payment systems (recitals 15 and 16). Article 5a(8) of the amended SEPA Regulation sets their dates.

The dates for verification of payee, price parity and screening in Articles 5b, 5c and 5d do not distinguish between banks and non-banks. The Commission's Q&A states that they apply to non-bank PSPs that already provide instant euro transfers, so a PI or EMI that starts offering instant transfers ahead of April 2027 applies price parity and daily screening from the first day. It also confirms that the verification of payee duty applies to PIs and EMIs when the payer is their customer. The ECB's deadline table likewise gives no separate verification of payee date for PIs and EMIs, and notes that the service covers standard as well as instant credit transfers.

Member States outside the euro area

The later dates apply where the Member State's currency is not the euro, for example a PI authorised by the Czech National Bank under the Czech payment institution licence or by the KNF in Poland. Two derogations apply there. With its competent authority's prior permission, renewable each year, a PSP may cap instant euro transfers sent from national currency accounts at a limit set by the authority of not less than EUR 25,000, at times when it neither sends nor receives standard euro transfers on those accounts. Until 9 June 2028 it need not offer instant euro sending from national currency accounts at those times at all.

A Member State that adopts the euro before 9 April 2027 follows Article 16(9): its PSPs comply within one year of adoption, not later than the dates for Member States outside the euro area and not earlier than the euro area dates. Bulgaria joined the euro area on 1 January 2026, so PSPs located there read their dates through this rule.

What instant means in practice

Article 5a sets the operating standard for every instant euro transfer. The payer's PSP checks the order and the funds immediately, reserves or debits the amount and sends it on. Within 10 seconds of receipt of the order, the payee's PSP makes the funds available on the payee's account and confirms completion. If no confirmation arrives within 10 seconds, the payer's PSP restores the payer's account and tells the payer, free of charge.

• Reachability: every account reachable for standard credit transfers is reachable for instant ones 24 hours a day, on any calendar day.
• Channels: instant orders can be placed through every channel available for other credit transfers, including in bulk where bulk files are offered.
• Customer limits: on request, the customer can set a maximum amount per day or per transaction and change it at any time.
• No regulatory ceiling: the IPR sets no maximum amount for an instant transfer.

For an EMI or PI the operational impact is significant. Treasury, liquidity, fraud monitoring and customer support all need to work outside business hours, because funds can arrive and leave on a Sunday night as easily as on a Monday morning.

Price parity

Under Article 5b, any charge for sending or receiving an instant euro transfer may not be higher than the charge the PSP levies for other credit transfers of the corresponding type, and verification of the payee is free for every customer. The Commission's Q&A explains that the corresponding type is judged on criteria such as the channel used, the customer's status and any added features.

Where several corresponding transfer types exist, the instant transfer may not cost more than the cheapest of them. In the Commission's worked example, a firm charging EUR 5 for a standard SEPA transfer cannot charge more than EUR 5 for an instant one. If a monthly fee includes a set number of standard transfers, at least the same number of instant transfers must be included.

PSPs also report to their competent authorities every 12 months on the level of their charges and on the share of payments rejected because of targeted financial restrictive measures. The first report was due on 9 April 2025.

Verification of payee

Article 5c requires the payer's PSP to check the payee before the payer authorises a credit transfer, whatever channel is used. Where the payer gives an IBAN and a name, the payee's PSP confirms whether they match. On a close match the payer sees the name held for that account; on no match the payer is warned that the money might go to an account not held by the intended payee. For legal persons the check can use another identifier, such as a tax number or Legal Entity Identifier, where both PSPs hold it.

Three points matter most for EMIs and PIs:

• Both roles: a PI or EMI performs the check for its own customers as payer's PSP, and answers checks as payee's PSP on accounts it maintains.
• Pooled and virtual accounts: where one account is held for several payees, the PSP that maintains it confirms, on request, whether the named payee is among them. This applies directly to models built on safeguarding accounts and virtual IBANs.
• Liability: a PSP that performs the check correctly is not liable when a customer pays the wrong account anyway. A payer's PSP that does not offer the check refunds the payer where a payment is defectively executed as a result.

Business customers sending bulk payments may opt out of the check and opt back in at any time. The ECB reports that the Eurosystem offers a verification of payee service built on solutions from Banco de Portugal and Latvijas Banka and designed to the European Payments Council's scheme.

Sanctions screening: daily, not per payment

Article 5d changes how PSPs that offer instant euro transfers apply EU asset freezes and prohibitions on making funds available. They screen their own customers against EU targeted financial restrictive measures at least once every calendar day, and immediately whenever new measures or amendments come into force. During an instant transfer, neither the payer's nor the payee's PSP screens the payer or payee against those targeted measures in addition to that customer screening.

The Commission's Q&A confirms that customer screening runs against the EU-wide lists adopted under Article 215 of the Treaty on the Functioning of the European Union, every calendar day including weekends. The rule does not change a firm's other sanctions obligations, its national measures or its AML duties, and PSPs that do not execute instant transfers continue as before. For many EMIs this means redesigning screening from a payment-level check to a customer-level process that runs at least daily and on every list update.

Payment system access and safeguarding

Direct access to designated payment systems

The IPR amended the SFD definition of "institution" to include PIs and EMIs, except firms exempt under Article 32 or 33 of PSD2 or waived under Article 9 of the E-Money Directive, so they can participate directly in designated payment systems. Member States had to apply this change and the matching PSD2 changes by 9 April 2025.

New Article 35a of PSD2 sets what a PI or EMI must have in place to request participation:

• a description of its safeguarding measures, including its investment policy, who can access the safeguarding account and its reconciliation process;
• a description of its governance, internal controls and ICT arrangements under Articles 6 and 7 of the Digital Operational Resilience Act (DORA);
• a winding-up plan suited to its size and business model.

Firms that do not join a system directly can still settle through a participant. A participant that gives one PSP indirect access must give other PSPs the same opportunity on objective, proportionate and non-discriminatory terms, with full reasons for any refusal. The ECB states that, as of October 2025, non-bank PSPs meeting the requirements of the TARGET Guideline can access T2 and TIPS, the Eurosystem's instant payment settlement service. Under the Eurosystem's access policy, these accounts hold only the funds needed for the current business day's settlement, and firms apply through their national central bank.

Safeguarding at a central bank

The IPR amended Article 10 of PSD2 so that safeguarded funds can be held in a separate account at a credit institution or, at that central bank's discretion, at a central bank. The Commission confirms central banks are not obliged to offer this, and the Eurosystem has stated that it will not provide safeguarding accounts to non-bank PSPs. For euro area firms safeguarding therefore continues through credit institutions, secure low-risk assets or insurance and guarantees, and the firm's safeguarding team builds those arrangements.

Readiness checklist for PIs and EMIs

A practical sequence is to choose the settlement route first, because it decides the technology, liquidity and contract work, then build verification of payee and screening, and finish with pricing, customer terms and staff training. Firms that start early can test with real volumes well before 9 April 2027.

What it means for a firm applying for an EMI or PI licence now

A firm applying today will usually be authorised close to the 2027 deadlines; the firm plans EU EMI and PI authorisations at 6 to 8 months after submission. A euro area institution authorised after 9 April 2027 that offers euro credit transfers must send and receive instant transfers, with verification of payee, price parity and daily screening, from its first day of business.

• Programme of operations: describe the instant transfer service, the settlement route and the 24-hour operating model in the application, not as a later change.
• One governance file: the safeguarding, governance, ICT and winding-up descriptions required by Article 35a overlap with the licence file, so drafting them once serves both the regulator and the payment system.
• Safeguarding: plan for credit institution accounts or the other permitted methods, since Eurosystem central banks will not hold safeguarded funds.
• Jurisdiction: euro area and non-euro Member States have different dates and derogations; our comparison of EU payment institution and EMI jurisdictions covers the wider choice.
• Infrastructure: some national systems already connect licensed PIs and EMIs to SEPA Instant and verification of payee, as described in our Lithuania EMI licence guide.

The next round of EU reform builds on the IPR: the Payment Services Regulation, not yet adopted, would extend name and IBAN checks to every credit transfer, as our guide to PSD3 and the Payment Services Regulation explains. The firm's EMI licensing team builds instant payments into applications from the start.

Frequently asked questions

References

1. Regulation (EU) 2024/886 on instant credit transfers in euro (EUR-Lex)
2. European Central Bank: Instant Payments Regulation, main requirements and implementation deadlines
3. European Commission, DG FISMA: Clarification of requirements of the Instant Payments Regulation (updated 28 July 2025)
4. European Central Bank: Eurosystem policy on access by non-bank PSPs to central bank payment systems (19 July 2024)
5. European Central Bank: Bulgaria joins the euro area

Speak to an expert: WhatsApp +44 7563 115980, Telegram @buckinghamcapital or [email protected].

This article is general information, not legal advice. Requirements change, and the regulator’s own publications take precedence.