SEPA

SEPA is fully supported by the European Commission, the European Parliament, the European Council and the Eurosystem, and is promoted by the European Central Bank.

In accordance with Regulation (EU) 2012/260, payment service providers’ payment accounts that are reachable for national credit transfers and direct debits should also be reachable for the same cross-border payment transactions. Reachability of accounts and interoperability between payment service providers as well as with retail payment systems are the sine qua non of SEPA’s success.

The following are regarded as PSPs:

• credit institutions;

• payment institutions;

• electronic money institutions;

• post office giro institutions;

• the European Central Bank and national central banks when not acting in their capacity as monetary or other public authorities;

• the Greek State and the other EU Member States, or their regional or local authorities when not acting in their capacity as public authorities.

The European banking community has set up the European Payments Council (EPC), which is responsible for the management and development of payment schemes. The SEPA payment schemes are the following:

• SEPA Credit Transfer (SCT);

• SEPA Instant Credit Transfer (SCT Inst);

• SEPA Direct Debit (SDD); and

• One-Leg Out (OLO) Instant Credit Transfer (OCT Inst).

A credit transfer is a national or cross-border payment service for crediting a payee’s payment account with a payment transaction or a series of payment transactions from a payer’s payment account by the PSP which holds the payer’s payment account, based on an instruction given by the payer.

A direct debit is a national or cross-border payment service for debiting a payer’s payment account, where a payment transaction is initiated by the payee on the basis of the payer’s consent.

An instant credit transfer is a credit transfer which is executed immediately, 24 hours a day and on any calendar day.

Regulation (EU) 2012/260 established technical and business requirements for credit transfers and direct debits in euro. Instant credit transfers in euro are a category of credit transfers in euro which was introduced by the  Regulation (EU) 2024/886.. Therefore, any specific requirements applicable to instant credit transfers in euro are laid down in Regulation (EU) 2024/886.

PSPs should be able to offer all credit transfers in euro initiated by their payment service users (PSUs) as instant credit transfers in euro by default.

PSPs that participate in SEPA payment schemes are able to provide their customers with payment instruments that comply with the specifications and rules of the respective schemes.

SEPA payment schemes clearly stipulate that the payer and the payee are each charged fees separately by their respective PSP.

Such fees may vary among PSPs, according to each PSP’s business plan and pricing policy, also taking into account the capacity of the user (consumer or business), the number of payment orders and the initiation channel of the payment order (e.g. physical branch, internet or smartphone).

In Greece, under Article 48 of Law 5167/2024, a maximum per-transaction charge of EUR 0.50 on both outgoing and incoming credit transfers amounting up to EUR 5,000 has been set for natural persons and sole proprietors between payment service providers within Greece.

In any event, charges levied by a PSP on a PSU in respect of cross-border payments are the same as the charges levied by that PSP on PSUs for corresponding national payments of the same value and in the same currency. This is provided for by Regulation (EC) No 1230/2021 of the European Parliament and of the Council of 14 July 2021 on cross-border payments in the European Union.

Furthermore, Regulation (EU) 2024/886 requires that charges for instant credit transfers in euro do not exceed charges for other credit transfers in euro. PSPs must thus ensure that charges levied for instant credit transfers in euro are not higher than the charges applied for corresponding types of non-instant credit transfers in euro.

The International Bank Account Number (IBAN) is the payment account identifier in SEPA and is created according to the international standard ISO 13616. In order for a SEPA payment to be effected, payers must provide their PSP with the payee’s ΙΒΑΝ. Even for payments between accounts held within the same PSP, the ΙΒΑΝ is exclusively used.

In Greece, the ΙΒΑΝ is composed of 27 alphanumerical characters, with the following structure:

GR 11 PSP 1234 0000001234567890, where:

• GR, the country code (two capital letters);

• 11, the check digits (two digits);

• PSP, the payment service provider code (three digits);

• 1234, the branch code (four digits); and

• 0000001234567890, the customer’s account number (16 digits – when the account is composed of less than 16 digits, leading zeros are added).

Special applications for checking the validity of an IBAN or for converting a simple payment account number into IBAN are available by the Hellenic Bank Association.

In some instances, companies (e.g. utility providers) or organisations (e.g. public sector entities or private sector employers) may refuse to accept a non-domestic IBAN (i.e. without country code “GR”) for payments in euro via credit transfer or direct debit.

This practice constitutes IBAN discrimination according to Article 9 of Regulation (EU) No 260/2012.

What is IBAN friction?

IBAN friction is a special form of IBAN discrimination related to technical infrastructure weaknesses that may prevent the seamless use of a SEPA IBAN. This can be attributed to:

• technological issues regarding outdated technology/non-updated payment software in ERP systems that rejects or is unable to validate non-domestic IBANs;
• bureaucratic practices, whereby an entity, while not straightforwardly and explicitly refusing payment (which would constitute IBAN discrimination), imposes extremely difficult and time-consuming conditions, such as requiring physical presence at a specific branch or submission of complicated forms, so that the use of a non-domestic IBAN is practically impossible for the transacting party.

In any case, cross-border payments within the SEPA area are thus prevented.

IBAN discrimination is prohibited

Within the SEPA area, discrimination based on the Member State where the euro payment account is held is not permitted. Every entity is obliged to accept, along with national IBANs, also every euro IBAN from all other EU and EEA countries, both for credit transfers and direct debits. In cases of IBAN discrimination, sanctions and fines are imposed.

Examples of IBAN discrimination

1. Salary payment

Following your recruitment by a company, you declare to your new employer the IBAN of your account, which is held with a bank of another EU country (e.g. Germany, starting with country code "DE"). The employer refuses to use it, stating that they only pay salaries to Greek IBANs that start with country code "GR". This is a case of IBAN discrimination, as the employer is obliged to accept any IBAN from a SEPA country.

2. Direct debits

A company within SEPA that offers its customers the option to pay for its products or services via direct debit is obliged to accept all IBANs issued within the SEPA area as payment accounts. Failure to do so constitutes IBAN discrimination.

What is NOT covered by the prohibition of IBAN discrimination

The prohibition of IBAN discrimination does not apply to:

• Savings or investment accounts, which are not considered payment accounts.
• Card payments and cash withdrawals: Payments made with a debit or credit card, as well as cash withdrawals from ATMs or bank branches, are not covered by the SEPA Regulation.

Reporting IBAN discrimination

If a company or organisation based in Greece rejects the IBAN of the euro payment account you hold in another SEPA country, you can follow the following steps:

1. Inform the entity you believe is implementing this practice that they are obliged to accept IBANs from other SEPA countries (Article 9 of Regulation (EU) No 260/2012).
2. Submit a formal written complaint to this entity.
3. If you do not receive a satisfactory response to your complaint, you can report the alleged violation to the Bank of Greece in its capacity as competent authority, via the BoG Information Centre on its official website.
4. In addition, you can make a relevant report to the EU through the Accept My IBAN platform.

PSPs in SEPA are identified by their Business Identifier Code (BIC), which is calculated according to the international standard ISO 9362. The Bank of Greece’s BIC is BNGRGRAA.

Under Regulation (EU) 2012/260, after 1 February 2016 payment service users are no longer required to indicate the BIC of the payee’s PSP for payment transactions in the form of credit transfers or direct debits. Users communicate to their PSP only the IBAN of the payee. It should be noted that PSPs are still required to use the BIC when processing interbank payment transactions.

For this reason, and for the information of every interested party, the following table lists the BICs of PSPs operating in Greece along with the corresponding Bank Identifiers (positions 5-7 of a Greek IBAN).

The international standard ISO 20022 XML provides the format to be used for preparing and transmitting all messages that contain SEPA payment information. It is used:

• between PSPs or PSPs and a retail payment system; and

• by PSUs other than consumers or micro enterprises when they initiate or receive batches of credit transfers or direct debits which are not transmitted individually, but are bundled together for transmission, to and from PSPs. 

Law 4141/2013, as amended by Law 5019/2023, provides as follows:

• The Bank of Greece is the competent authority for ensuring compliance with Articles 3, 4, 5 and 9 of Regulation (EU) 2012/260.
• The General Secretariat of Commerce of the Greek Ministry of Development and Investment is the competent authority for handling complaints under Articles 7 and 8 of Regulation (EU) 2012/260 and imposing the relevant sanctions.
• Regarding any out-of-court settlement of disputes arising between PSUs and PSPs concerning their rights and obligations under Regulation (EU) 2012/260, the competent bodies are the Hellenic Consumers’ Ombudsman and the Hellenic Financial Ombudsman.

Citizens of SEPA countries can pay taxes and duties via SEPA Credit Transfer. In Greece, the relevant instructions are provided by the Independent Authority for Public Revenue (IARP/AADE) and the Taxpayers’ Customer Service.