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Effectively, this means that as of this date, existing national euro credit transfer and direct debit schemes will have to be replaced by the SEPA Credit Transfer (SCT) and SEPA Direct Debit (SDD) Schemes. The majority of market participants recognise the value of setting a deadline for migration to harmonised SEPA payment schemes through European Union (EU) Regulation. The EPC shares the view that an end date for phasing out legacy euro payment schemes for credit transfers and direct debits ensures planning security for all market participants.
The European Payments Council (EPC) has frequently pointed out that full migration to SEPA is subject to the appropriate legal and regulatory environment which must be established by the EU legislator. The substantial efforts of the banking industry to develop harmonised SEPA payment schemes, as requested by the EU authorities, did not - and, in light of EU antitrust law, could not - entail a responsibility of the industry to impose the replacement of existing national schemes by the new SEPA instruments. The fact that the mere existence of harmonised SEPA payment schemes did not trigger mass migration on the customer side did not come as a surprise. It must be highlighted as often as necessary that the SEPA process would never have occurred spontaneously; bank customers never asked for it.
The SEPA Regulation empowers the European Commission to amend the technical requirements set out in the Annex to the Regulation through ‘delegated acts'. When adopting these acts, the European Commission has committed to consulting experts appointed by EU governments in its preparatory work. It is uncertain to what extent the European Commission will consult SEPA stakeholders not appointed by EU governments. The European Commission has reiterated that it has a lot of autonomy in relation to adopting delegated acts and "experts will have a consultative rather than an institutional role in the decision-making procedure".