27 March 2006

ZKA comments on SEPA

The German ZKA issued its comments on the Commissions Consultative Paper on Sepa Incentives published in February criticizing the Commission’s allegations that the new schemes do not provide an adequate reflection of customers' interests. ZKA also complains that the Commission expresses clear doubts vis à vis the banking industry's self-regulation capabilities, adding that the Commission to date failed to show a demonstrable case of market failure that would permit to take regulatory action in line with the Commission's better regulation principles. The mere potential risk of market failure alone is not a sufficient justification for regulatory action, ZKA argues.

As far as the implementation stage is concerned, there is hence a compelling need to ensure that the fundamental basics and the scope of the SEPA project are not being called into question at its very outset. In line with the EPC Roadmap 2004 – 2010, ZKA asks that neither the Commission nor the legislator call into question the scope of the SEPA project at short notice in an unexpected manner. Such a development would jeopardise successful implementation of the entire project.

ZKA emphasises the need for timely creation of a legal framework for payments in the internal market. Hence, there is a need for prioritisation by way of limiting the European Commission's Proposal for a Directive to what is needed for realisation of SEPA. Whilst the law governing credit transfers and card payments already features a sufficient degree of harmonisation, the only remaining area where there is still a genuine need for regulatory action is the forthcoming SEPA direct debit scheme. In order to lend timely support to SEPA realisation, it will be sufficient to adjust those regulatory provisions – for instance concerning authorisation, revocability and refund of direct debits – which are required for a European direct debit scheme.

Press release

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