With the Instant Payments Regulation (IPR) becoming a compliance mandate across the EU, many Payment Service Providers (PSPs), Electronic Money Institutions (EMIs), and Financial Institutions (FIs) are preparing to join the Verification of Payee (VoP) Scheme.
But here’s the question:
Are you really ready to adhere to the VoP Scheme requirements?
The European Payments Council (EPC) has laid out a clear path in the VoP Adherence Guide and Rulebook — and it starts with knowing the exact conditions to adhere.
In this blog, we will list down the five conditions every applicant must meet to complete the VoP adherence process. This readiness assessment will help you avoid costly delays, surprises, or compliance gaps.
Start Here: Familiarise Yourself with the Adherence Process
Before jumping into the application process, the EPC strongly advises all applicants to:
- Carefully review Section 4.4 of the VoP Rulebook (Eligibility for Participation)
- Explore Section 4 of the VoP Adherence Guide
- Create an internal checklist of required documents, processes, and systems
Why is this important?
These steps will help you with below and help create a list of own documentation which will be needed to support or be used in the adherence process.
- Design Institutions internal VoP adherence workflow
- Plan timeline and resourcing
- Allocate the right budget and legal support
- Identify key technical and compliance gaps early
What Are the EPC’s 5 Conditions to Adhere?
Let’s break down the core conditions every applicant must fulfil to formally join the VoP Scheme:
Condition 1: Meet All Eligibility Criteria
This is non-negotiable.
Institution looking to participate must satisfy all eligibility requirements under Section 4.4 of the VoP Rulebook at the time of application — and continue to meet them throughout the participation in EPC VoP scheme.
That includes ongoing compliance with:
- Participant obligations in Sections 4.7, 4.8, and 5.3 of the Rulebook
- Regulatory standards (licensing, solvency, AML, capital requirements)
Condition 2: Have a Valid Identifier (BIC)
Every VoP Scheme participant must be uniquely identified using a valid Business Identifier Code (BIC).
Accepted identifiers:
- BIC8XXX
- BIC11
Not accepted (but can be shared with the Secretariat for reference):
- Legal Entity Identifier (LEI)
- Local business or trade register numbers
Condition 3: Pay the Scheme & EDS Fees
To complete the adherence process and get access to the EPC Directory Service (EDS), participants must:
- Pay the VoP Scheme participation fee
- Pay all EDS-related onboarding and maintenance fees
This is required before moving to the onboarding stage.
In the frame of the mandatory participation to VOP Scheme and mandatory registration and funding of EDS approved by the PSMB and by the EPC Board, all SEPA SCT Inst and/or SCT Schemes’ participants that didn’t explicitly opt-out by 31 January are being invoiced by the EPC.
EPC expects invoicing to be completed as of April 2025.
Adherence Waves and access to EDS Directory
Access to the EPC Directory Service (EDS) is essential for going live with Verification of Payee — without it, participants will not be reachable under the Scheme. To manage onboarding, the EPC has introduced a wave-based timeline, and your EDS access depends entirely on when you start the adherence process.
Here’s how it works:
- Wave 1: If your adherence request and fees are submitted between 24 March and 15 May 2025 (by 18:00 CET), and your documental adherence is completed successfully, EDS access will be granted by 15 August 2025.
- Wave 2: Submissions between 16 May and 30 June 2025 (by 18:00 CET) will receive EDS access by 10 September 2025.
- Wave 3: Requests submitted after 30 June 2025 will be handled on a best-effort basis, with no guaranteed timeline for EDS access.
Early adherence = guaranteed access = go-live readiness.
Delaying = risk of operational delays and regulatory non-compliance.
Let TechnoXander Act as Your Adherence Agent
Navigating VoP Scheme adherence can be resource-intensive — from compiling legal documentation to managing technical inputs. At TechnoXander, we act as agents on your behalf to streamline this process. We help institutions complete their adherence packs, validate requirements, manage documentation, and coordinate with the EPC Secretariat where needed.
Whether you’re a bank, EMI, or payment provider, we bring hands-on experience to ensure your application is accurate, complete, and submitted on time — so you can focus on running your business.
To ensure smooth onboarding and a timely go-live, we strongly recommend starting the VoP adherence process immediately.
Condition 4: Complete EDS Onboarding
What is the EDS?
The EPC Directory Service (EDS) is the backbone for ensuring interoperability and reachability between VoP participants.
To officially join the Scheme and become reachable, participants must:
- Complete your onboarding in the EDS
- Provide all necessary institutional and technical data
Condition 5: Update Reachability Data and ORD in the EDS
Your job’s not done once you onboard — you must keep your reachability data and Operational Readiness Date (ORD) current within the EDS.
Here’s what you’ll need to provide:
- PSD2 Authorisation Number (NAN)
- API Endpoints (URIs)
- Optional identifiers (e.g., LEI, VAT number)
Depending on your role — Requesting PSP, Responding PSP, or both — this data is crucial for real-time VoP communication and Scheme-wide interoperability.
TechnoXander Can Help You Complete Your EDS Directory — End-to-End
As a Qualified Routing and Verification Mechanism (RVM) provider, TechnoXander is equipped to fully manage your EDS directory onboarding. We bring proven experience through our role in the Pay.UK Confirmation of Payee (CoP) directory, where we’ve successfully handled directory submissions and updates for a wide range of institutions.
Notably, we are an approved aggregator and the only aggregator eligible to sell to public organisations under the UK Crown Commercial Service (G-Cloud 14) supplier agreement. This means we don’t just understand the requirements — we know how to get it done, fast and right.
Need Help Getting Started?
As a VoP provider and Authorised Agent, we’ve helped PSPs and EMIs across Europe navigate VoP compliance — from eligibility and onboarding to live VoP traffic.
Book a VoP Adherence Planning Session with our team — and get started Now!
What’s Next?
🧾 “The Full VoP Adherence Documentation Guidance”
What you need. Who needs to sign. And how to avoid delays.
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