The European Payments Council (EPC) has released a key document for financial institutions preparing for compliance with the Verification of Payee (VoP) under the Instant Payments Regulation (IPR): the VoP Adherence Guide.
This guide outlines the path for joining the VoP Scheme, a requirement that will soon affect Payment Service Providers (PSPs), Electronic Money Institutions (EMIs), and other financial institutions operating within SEPA.
As we speak to various PSPs, EMIs, and banks preparing for VoP implementation, one recurring question comes up:
“Are we eligible to participate in the VoP Scheme — as a requestor, responder, or both?”
In this blog, we discuss the eligibility criteria for VoP participation — and account for requirements under Section 4.4 of the VoP Rulebook and Section 4 of the Adherence Guide.
First Step: Preliminary Self-Assessment
The EPC is advising all potential participants to perform a preliminary self-assessment before embarking on the VoP Adherence pack submission. Below are key considerations which PSPs must evaluate before starting EPC VoP process:
- Are you legally established and regulated?
- Is your institution technically ready to meet VoP specifications?
- Are you aligned with the scheme’s operational and risk requirements?
This self-check helps institutions gauge regulatory, technical, and financial readiness to participate.
Who is eligible as Responder & Requester in the VoP Scheme?
According to the updated SEPA Regulation (EU) 260/2012, as amended by the Instant Payments Regulation (EU) 2024/886, two categories of participants are recognised:
Responding Side Eligibility
• Account Servicing Payment Service Providers (ASPSPs)
• These are PSPs that hold the customer account information required for a VoP check
• They participate in the SCT or SCT Instant schemes
Requesting Side Eligibility
• Payment Initiation Service Providers (PISPs) can also apply, in addition to ASPSPs
• PISPs initiate payments and are legally required to perform VoP checks before initiating SEPA Instant payments
Key condition:
PISPs must perform VoP checks before initiating SEPA Instant Payments, as mandated by IPR.
Who Is Automatically Eligible?
Wondering if your institution is already covered under VoP participation rules?
The following types of organisations are considered to automatically satisfy the eligibility criteria:
- Credit institutions authorised under Article 8(1) of Directive 2013/36/EU
- Institutions listed in points (2) to (23) of Article 2(5) of Directive 2013/36/EU, such as:
- Electronic Money Institutions (EMIs)
- Post office giro institutions
- PSPs authorised under Article 11 of PSD2
- Any other payment service providers listed under Article 1(1) of PSD2
If you’re in one of these categories, your path to adherence might be more straightforward — but don’t skip the details.
Full Eligibility Criteria – VoP Rulebook Section 4.4
For an institution to become and remain a VoP Scheme Participant, it must meet all of the following criteria:
- Be licensed as a PSP
- Be incorporated or licensed in a SEPA country or regulated by an appropriate EEA body
- Not be insolvent or in financial distress
- Maintain adequate liquidity and capital, in line with regulatory requirements
- Comply with AML/CFT and sanctions regulations
- Implement proper operational and risk controls
What About Branches?
If your institution operates branches within SEPA, it’s important to note:
A non-subsidiary branch cannot apply separately — the legal entity must apply, and all branches within SEPA are then covered under that entity’s adherence.
What Identifier Do You Need?
Applicants must use a valid Business Identifier Code (BIC) when joining the Scheme:
- Accepted identifiers:
BIC8XXX or BIC11
- Not accepted (but can be shared):
Legal Entity Identifier (LEI)
National trade register or enterprise numbers
Summary: Are You VoP-Eligible?
If you’re:
- A licensed PSP or PISP
- Participating in SCT/SCT Inst
- Operating within SEPA/EEA
- Compliant with AML and financial regulations
Then you’re likely eligible — and possibly mandated— to join the VoP Scheme under the IPR timeline.
Ready to Get Started with VoP?
As a Qualified RVM and Agent for VoP Adherence process, TechnoXander is already working with PSPs, EMIs, and FIs to help them assess eligibility, prepare Adherence pack, and accelerate their VoP journey.
Book a free VoP readiness call with our VoP experts today.
Coming Up Next:
In our next blog, we’ll walk you through the VoP Adherence Process, the documents you need, and the role of Agents like us in simplifying it.
Stay tuned — or subscribe to get it straight to your inbox.
