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Particularly, EAPB is dissatisfied with mandatory execution time D+2, especially because non-Euro currencies are included. In EAPB’s opinion, a maximum execution time of three days would be appropriate and also meet customers’ needs. Furthermore, a short execution time will increase the costs for payments.
The EAPB also welcomes the limitation of the scope of the Directive to payments within the EU. The extension of the scope, as proposed by the Commission, to payments in non-EU currencies is clearly contrary to the aim of the Directive to create an Internal Market for payments in the EU.