We highlight our support for efforts to increase the uptake of SCT Inst and the view that SCT Inst could facilitate stronger and more integrated homegrown pan-European payment solutions. It is necessary to carefully assess which actions by the public authorities could enable the further development of instant payments and which aspects would be best left to market developments, with the potential monitoring by the public authorities.
      
    
    
      The EBF  has responded to the European Commission’s Have-Your-Say 
consultation ‘Inception Impact Assessment’ on instant payments.  Market-led developments and uptake by market participants 
should be favoured and any eventual legislative action should be limited
 to the building blocks needed for widespread adoption of SCT Inst and 
the resolution of any hindering factors.
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The EBF  supports efforts to increase the uptake of SCT Inst and the view that SCT Inst could facilitate stronger and more integrated homegrown pan-European payment solutions. As the European Commission is strongly supporting the further development of instant payments and instant payments-based solutions, we understand that it is necessary for the Commission to evaluate the need for potential non-legislative and legislative actions. It is in our view necessary to carefully assess which actions by the public authorities could enable the further development of instant payments and which aspects would be best left to market developments, with the potential monitoring by the public authorities. Market-led developments and uptake by market participants should be favoured and any eventual legislative action should be limited to the building blocks needed for widespread adoption of SCT Inst and the resolution of any hindering factors. The Commission should investigate necessary basic parameters to support further instant payment solutions in a market-driven environment. With regard to the specific topics that the IIA considers could be part of a possible legislative initiative, we make specific comments on some of them in section 2..... 
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