Instant Payments Regulation: 2027 Deadlines and VoP

The EU Instant Payments Regulation is no longer only a topic for eurozone banks. Its remaining deadlines fall between January and July 2027, and they reach payment institutions, e-money institutions and payment service providers outside the euro area. For payment service providers in Bulgaria, which adopted the euro on 1 January 2026, the date is 1 January 2027.

This guide sets out who is affected, when, and what the regulation requires in practice: instant euro transfers, price parity, Verification of Payee (VoP) and a new approach to sanctions screening. It closes with the points that are most often misread.

Checked against Regulation (EU) 2024/886, the European Commission’s Q&A on its implementation (July 2025 update) and the EPC Verification Of Payee scheme rulebook (version 1.1) on 16 March 2026. This guide explains the regulation in plain language. It is not legal advice.

Your deadline at a glance

The regulation amends the SEPA Regulation (EU) No 260/2012 and phases its obligations in by location and by type of institution. “Banks” in the table covers all payment service providers other than payment institutions and e-money institutions.

You are	Receive instant euro transfers	Send instant euro transfers	Price parity	Verification of Payee
Bank in the euro area (except Bulgaria)	9 Jan 2025	9 Oct 2025	9 Jan 2025	9 Oct 2025
Payment or e-money institution in the euro area (except Bulgaria)	9 Apr 2027	9 Apr 2027	9 Jan 2025	9 Oct 2025
Any payment service provider in Bulgaria	1 Jan 2027	1 Jan 2027	1 Jan 2027	1 Jan 2027
Bank in a non-euro EU country	9 Jan 2027	9 Jul 2027	9 Jan 2027	9 Jul 2027
Payment or e-money institution in a non-euro EU country	9 Apr 2027	9 Jul 2027	9 Jan 2027	9 Jul 2027

Why Bulgaria has its own row. Countries that adopt the euro before 9 April 2027 must comply within one year of their euro date, and never later than the deadlines for non-euro countries (Article 16(9)). The Bulgarian National Bank states in its SEPA FAQ that payment service providers in Bulgaria must offer instant euro transfers from 1 January 2027, and that every payment service provider licensed in Bulgaria must provide Verification of Payee from the same date.

One date applies everywhere: the sanctions screening rules have applied since 9 January 2025 to every payment service provider that offers instant euro transfers, or from the first day it offers them.

Who is in scope

The core obligation is simple: a payment service provider that offers its customers euro credit transfers must also offer sending and receiving instant euro transfers to all of them. It sits with the provider that holds the customer’s account.

In scope:

• All payment institutions and e-money institutions, including small ones, whether or not they participate directly in a payment system
• Savings and cooperative banks
• Accounts in any currency, where euro transfers are offered from them

Out of scope:

• Transfers processed and settled through large-value payment systems
• Card payments and money remittance
• E-money transfers that do not credit or debit an IBAN account

Two practical tests:

• Is it a payment account? An account counts only if payments to or from third parties can be made with it. A savings account that can only be reached through a linked current account is not one.
• Where is the provider located? Deadlines follow location, so a branch in the euro area of a head office outside it uses the euro-area dates.

Obligation 1: offer instant euro transfers

• 24/7 reachability. Every account that can receive credit transfers must be reachable for instant euro transfers 24 hours a day, every calendar day.
• Ten seconds, end to end. Within 10 seconds of the payer’s provider receiving the order, the payee’s provider must make the funds available, in the account currency, and confirm. The payer’s checks and funds reservation happen inside that window, not before it.
• No grace period. If no confirmation arrives within 10 seconds, the payer’s account is restored immediately. There is no extra time to query the clearing system, no automatic resend and no automatic switch to a regular transfer.
• Tell the payer. The payer, and the payment initiation service provider where one is used, must be told the outcome, free of charge.
• Same channels. Instant must be available wherever regular euro transfers are: online, mobile, branch, phone, bulk files, future-dated and recurring orders.
• Customers set the limits. Customers can set a maximum per day or per transaction and change it at any time with immediate effect. Providers may not impose instant-only caps such as the former €100,000 limit; any limit a provider sets must apply to regular transfers too.
• Maintenance. Short, planned maintenance is allowed if customers are told in advance.

Providers outside the euro area have two narrow exceptions for sending instant euro transfers from accounts held in their national currency, one of which runs until 9 June 2028.

Obligation 2: charge no more than for a regular transfer

An instant euro transfer may not cost the payer or the payee more than the corresponding regular euro transfer. “Corresponding” means the same channel and the same type of customer. Where several regular options correspond, the cheapest sets the ceiling. An example from the Commission’s Q&A: with regular SEPA at €5, instant at €6 and SWIFT at €7, the instant charge must come down to €5. A package that includes a number of regular transfers must include at least as many instant ones.

Two further points:

• Services on top can be priced. The rule covers the transfer itself, not additional features built on it. The regulation names payment initiation, dispute resolution and refunds as examples.
• Verification of Payee is always free for customers.

Obligation 3: verify the payee before every euro transfer

This is the obligation that changes the customer journey most. Before the payer authorizes a euro credit transfer, instant or regular, the payer’s provider must check the payee and tell the payer the result. The check applies in every channel, 24/7, including to saved beneficiaries (every time), transfers between accounts at the same provider, standing orders (at set-up) and future-dated payments.

What the payer sees

• Match: an optional confirmation.
• Close match: the name held for the account is shown to the payer.
• No match: a notification that authorizing the payment may send the money to an account not held by the intended payee.
• Check not possible: for example if the account is closed or the payee’s provider cannot be reached.

Whatever the result, the payer decides; the check must never block authorization. The Euro Retail Payments Board has published guidance on wording these messages.

Four ways to verify

1. IBAN and name. The payee’s provider checks the name against its own records. For a person that means first name and surname; for a company, its legal or commercial name.
2. IBAN and an identifier. For companies, where the channel accepts it and the payee’s provider holds it: an LEI, fiscal number or European unique identifier. There is no “close match” for identifiers.
3. Accounts held for several payees. Payment and e-money institutions may hold customer funds in one account. The payer can add details such as a sub-account ID, and the provider confirms whether the payee is among the account’s customers.
4. Channels where the payer does not type both details, such as payments to a phone-number proxy. Here the payer’s provider must make sure the payee is correctly identified, show the payer enough to validate the payee, and keep robust procedures to ensure payee information is correct.

For payment requests initiated by the payee, the Commission’s Q&A places a similar duty on the payer’s provider: make sure the payee information is correct, and in practice show the payer the payee’s full name.

Where a payment initiation service provider supplies the payee details, it is responsible for their accuracy, and the payer’s bank should not run its own check unless asked to.

Opting out, and who pays when it goes wrong

• Opt-out: only business customers, only for payment orders submitted as a batch, and they can opt back in at any time. Consumers cannot opt out, and single payments cannot be opted out.
• When a provider is not liable: a provider that performed the check correctly is not liable if a payer ignores a warning and the money reaches the wrong account.
• When it refunds: if the payer’s provider fails to perform the check and the payment is executed defectively as a result, it refunds the payer without delay. If the failure was caused by the payee’s provider, that provider compensates the payer’s provider.
• Customers must be told about these consequences.

How providers exchange checks

The European Payments Council’s Verification Of Payee scheme provides common rules for these checks. Participants register in the EPC Directory Service and exchange checks through a common API. The answer must arrive within five seconds (preferably one); without it, the check counts as not possible.

Result	Code	Meaning
Match	MTCH	Details match
Close match	CMTC	Nearly match; name returned
No match	NMTC	Details do not match
Not possible	NOAP	Check could not be performed

Until 9 July 2027, payee providers in non-euro countries may receive instant euro transfers without yet having to answer checks. In that case the payer is told the check is not possible, and neither provider is liable for the missing check.

Payment and e-money institutions in the euro area (outside Bulgaria) should note that the Verification of Payee deadline makes no distinction between banks and non-banks: it has applied to them since 9 October 2025, even though their instant payments deadline is April 2027.

Obligation 4: screen your customers daily, not each payment

Providers that offer instant euro transfers must check whether any of their customers are subject to EU asset freezes or bans on making funds available. The checks run:

• at least once every calendar day, and
• immediately after new or amended measures enter into force, even if that means a second run the same day.

The Commission expects the whole process, including handling alerts, to be completed promptly rather than on the next business day. A flagged customer’s instant payments are suspended until the alert is cleared.

In exchange, individual instant transfers are no longer screened against those EU lists while they are executed. Other sanctions and anti-money-laundering controls continue to apply. For breaches of these screening rules, national penalty regimes must allow fines of up to at least 10% of annual net turnover for companies and at least €5 million for individuals.

Also required: reporting and access to payment systems

• Annual reporting. Every payment service provider reports to its competent authority on the level of charges for credit transfers, instant transfers and payment accounts, and on payments rejected because of EU sanctions. Reports use the templates set by Implementing Regulation (EU) 2025/1979. This includes providers outside the euro area.
• Payment system access. Payment institutions and e-money institutions can now become participants in designated payment systems, provided they meet conditions on safeguarding customer funds, governance and winding-up plans. Access is not automatic.

Ten points that are easy to get wrong

1. Bulgaria is not on the non-euro timeline. According to the BNB, the date for all payment service providers there is 1 January 2027.
2. Verification of Payee covers regular SEPA transfers, not only instant ones.
3. Euro-area payment and e-money institutions have owed VoP since October 2025, well before their instant deadline.
4. Sanctions screening has one start date everywhere; there is no 2027 date for non-euro countries.
5. From the sending deadline, there is no bank-set €100,000 cap on instant payments.
6. Ten seconds means ten seconds. No grace period, no resend, no automatic downgrade.
7. Saved beneficiaries are checked on every payment, not once.
8. Only business customers can opt out of VoP, and only for batches.
9. Customer limits are per day or per transaction, not both, and apply across all channels.
10. When a payment initiation service provider supplies the payee details, the bank should not re-run the check unless asked.

A practical roadmap

1. Scope and gap analysis. Map entities, accounts, channels and deadlines; run a requirements self-assessment.
2. Design. Decide the clearing route, 24/7 liquidity, pricing, the VoP set-up (direct scheme connection or a provider) and the screening model.
3. Build and adhere. Implement instant sending and receiving, VoP as payer’s and payee’s provider, and scheme adherence and directory registration.
4. Terms and communications. Update framework contracts, VoP messages, opt-out forms and notices.
5. Test. Cover every VoP outcome, the 10-second cycle, the five-second check and 24/7 operation.
6. Go live and report. Monitor timings and outcomes, and prepare the annual report.

The implementation pack below contains a template for each step.

payware perspective: instant payments at the point of interaction

Most of this guide is about obligations. The regulation also changes the economics of account-to-account payments at the checkout.

• Services on top of the transfer can be priced. The regulation limits what a provider can charge for the instant transfer itself, not for the services built on top of it.
• Checkout technology is under review. By 9 April 2027 the Commission must report on remaining obstacles to instant payments, including how standardized technologies such as QR codes, NFC and Bluetooth are.

payware connects payment institutions and merchants for account-to-account payments initiated by QR code, barcode, text, link, NFC, BLE and soundbite. Learn how it works for payment institutions.

Verification of Payee when payment details come from a network

In a payware payment the payer does not type the merchant’s IBAN or name. The payer’s institution receives the details the merchant registered on the network and shows them before the payer authorizes.

That does not move the obligation. payware is not a payment initiation service provider, so the carve-out for payee details supplied by a payment initiation service provider does not apply. The payer’s institution remains responsible for identifying the payee correctly and for showing the payer who they are paying before authorization, as in the fourth case above.

payware verifies registering users and checks that the account identifier is valid. payware does not confirm who holds the account: only the payee’s own payment service provider can do that, through Verification of Payee. One practical point for institutions building on any network of this kind: the payee name a network relays is often a trade or display name, while Verification of Payee matches against the name the payee’s provider holds for the account. Where the two differ, a correctly executed check returns a close match or no match on a legitimate payment. Decide early which name you send to the check, and what you show the payer when the two disagree.

Frequently asked questions

Does Verification of Payee apply to regular SEPA credit transfers?
Yes. It applies to every euro credit transfer, instant or regular, before the payer authorizes it.

Can a bank still cap instant payments at €100,000?
No. From the sending deadline, providers may not set limits that apply only to instant transfers. Customers can set their own limit, and any limit a provider sets must apply to regular transfers as well.

What is the deadline for payment service providers in Bulgaria?
According to the Bulgarian National Bank, 1 January 2027 for sending and receiving instant euro transfers and for Verification of Payee.

Do payment and e-money institutions need Verification of Payee before their instant payments deadline?
In the euro area (outside Bulgaria), yes: the VoP deadline of 9 October 2025 applies to banks and non-banks alike. In non-euro EU countries the date is 9 July 2027, and in Bulgaria 1 January 2027 according to the BNB.

Can business customers opt out of Verification of Payee?
Only for payment orders submitted as a batch. Single payments cannot be opted out, consumers cannot opt out, and a business can opt back in at any time.

Downloads and next steps

Two things to take away, both below. The readiness checklist is two pages: the deadline that applies to you and forty checks across the four obligations, free and with no sign-up. The implementation pack is the working set behind it, a requirements self-assessment, a project plan, Verification of Payee test cases and draft customer communications, sent to a work address.

Planning instant payments at the point of interaction? Talk to payware.

For background, read why instant settlement matters beyond speed and how payment institutions integrate with payware.