BANCA D’ITALIA
E U ROS IST EMA
National Migration Committee
SEPA Project
The National Migration Plan
May 2007
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Contents
1. Summary
2. Italy and the migration process
2.1. The organization
2.2. The position of the various actors in the migration process
3. The National Migration Plan for Italy
3.1 Credit transfers
3.1.1 Adoption of basic SEPA framework starting from 2008
3.1.2 Payment services under study
3.1.3 Non-migrating payment services
3.2 Direct debits
3.2.1. Direct debits that will migrate starting from 2008
3.2.2 Direct debits under study
3.2.3 Non-migrating direct debits
3.3. AOS under study
3.4. Credit and debit cards
3.5 Cash
3.5.1. The Recycling Framework
3.5.2. The SECA Framework
3.6. Communication and training: SEPA Project support
3.7. Further study on the Plan
3.7.1. IBAN – International Bank Account Number
3.7.1.1. IBAN Strategy
3.7.2. Focus on the analyses of non-bank stakeholders
3.7.2.1. Corporates
3.7.2.2. Central government departments
3.7.2.3. Local government
3.7.2.4. Consumers
3.7.2.5. Infrastructure
4. Open questions and problems
4.1. Delay and problems in transposing the Payment Services Directive
4.2. SEPA and reporting requirements
4.3 B2B direct debits
4.4. SEPA card framework – Interoperability standards
4.5. Defining AOS
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1. Summary
The European Payments Council (EPC), as the European banking industry’s decision-making
and coordinating body for the creation of the Single Euro Payments Area, has defined the regulatory
framework that will enable all citizens, corporates and public administrations, regardless of where
they are in Europe, to make and receive payments in euro on the same basic conditions and with the
same rights and obligations in all countries. The EPC’s SEPA Roadmap for 2004-2010 fixes the
following key stages, agreed with the Eurosystem, for completion of the project:
• by January 2008 the banking system must offer customers products and services under the
SEPA framework, guaranteeing the possibility of using pan-European as well as national
instruments;
• by the end of 2010 a critical mass of payment flows (credit transfers, direct debits, cards) must
have migrated to the pan-European schemes and the payment infrastructures must have been
completely adapted to the new reality of SEPA.
While the launch date of 1 January 2008 remains confirmed, the generalized availability of
SEPA Direct Debit may not come until later, given the delay in the approval of the Payment
Services Directive (PSD), and in order to ensure the greatest possible effectiveness of the
instrument and its responsiveness to the needs of the stakeholders.
National and European authorities are taking part in the implementation of the SEPA
Rulebooks. The Eurosystem (the European Central Bank and the euro area National Central Banks)
is responsible for the smooth functioning of payment systems and accordingly devotes special
attention to SEPA. The European Commission has developed a strategy to remove barriers within
the single market and is constantly monitoring the SEPA implementation programme.
Italy has created an ad-hoc organization to guide and monitor the implementation of SEPA: the
National SEPA Migration Committee, co-chaired by the Italian Bankers’ Association (ABI) and
Banca d’Italia. The Committee includes representatives of the main categories of final users of
payment instruments (corporates, public administration, merchants, consumers), who have been
asked to set up their own, internal coordination structure.
This National Migration Plan, drafted in interaction with all the stakeholders,
represents the Italian position on migration to SEPA.
Any changes to SEPA instruments approved by the EPC will form an integral part of this
National Migration Plan and will be duly implemented by the Italian banking system, in
interaction with non-bank stakeholders. The Plan should not be viewed as a final act but as
the point of departure of the SEPA project in Italy.
The members of the National SEPA Migration Committee undertake to cooperate pro-
actively to ensure that the implementation of the project does not result in any deterioration
in the functions characterizing the present payment services. In particular, if it should prove
impossible to serve the needs of final Italian users through the instruments envisaged in the
Rulebooks, every possible effort will be made for the prompt closing of the gap between the
“basic” instruments and those currently provided by the Italian banking system by means of
appropriate additional optional services (AOS).
The community AOS will be determined in direct interaction between the banking system and
the other stakeholders within the Consultation Forum. Once Italian community AOS have been set,
corporates will work together with the banking industry to make sure that those developed in Italy
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are promoted in the appropriate fora with a view to their broadest possible diffusion within the EU
and, hopefully, their inclusion in future versions of the Rulebooks.
To foster these processes, rules for consultation will be agreed on to facilitate transparency and
information sharing in the interaction between stakeholders and banks.
2. Italy and the migration process
2.1. The organization
As the EPC advised, Italy has organized a National Committee for the control, governance and
consultation on the actions undertaken to comply with the “SEPA timetable”, with a general plan
for meeting the EPC milestones.
National Committee
SEPA
National Committee
Organization – SEPA ad hoc
Project of Italian banking
system
Steering Committee/ C.E. ABI
P.A. System/ Corporates Consumer
Public org. System System
SEPA
Technical Secretariat
Coordination Committee
Technical
interbanking
Processors
Escalation of
SEPA Consultation each sector
Forum inside its
organizational
structure
Legal subjects Payments Collection / Cards Cash Standard Communicatio Referents of Consumers Corporates Central /
Direct Debit n/Events organiz. local P.A.
banking
structure
ABI Cross-divisional Committee
The National SEPA Migration Committee
Italy’s organization for the migration to SEPA is the National Committee, co-chaired by the
Italian Bankers’ Association (ABI) and Banca d’Italia. The Committee’s tasks include setting
guidelines and monitoring implementation. Formed in the first half of 2006, the Committee has held
two meetings, in July and December 2006. The Committee provides for the active participation of a
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number of institutions and associations, to make sure that all interests and stakeholders are
represented:
a. Public administration
b. Business associations
c. Consumer associations
d. Post office (Poste Italiane)
e. Interbank Convention on Automation (CIPA)
f. Association for Interbank Corporate Banking (ACBI) (observer status)
g. CO.GE.BAN (Convention for the management of the Bancomat trademark) (observer status).
Banking system internal structure
The banking industry has set up a steering committee, which makes strategic decisions on
operations, infrastructure, IT and communication, and a coordinating committee. They are served
by a technical secretariat.
Operatively, the structure provides for 10 working groups comprising banking industry experts
and stakeholder representatives, to ensure that the real needs of the market are served. The working
groups are:
1) Legal
2) Payments
3) Direct debits
4) Cards
5) Cash
6) Standards
7) Communication, Training, Image
8) Consumers
9) Corporates
10) Central and local government
In addition, there are infrastructure operators which, as suppliers of clearing and settlement
services to banks, do not take part in the National Migration Committee. The Italian Bankers’
Association - ABI), Banca d’Italia (as payment system oversight authority) and the SEPA technical
secretariat have begun direct cooperation with these operators in order to monitor their projects for
adaptation to SEPA.
Stakeholders internal structure
The stakeholders (corporates, public administration, merchants, consumers) have undertaken to
set up a structure of their own to cooperate with the banking system in devising the migration plan.
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Corporates
Business enterprises are represented on the National Committee by AITI (the corporate
treasurers association), Confindustria (the Confederation of Industry), and the trade and
commerce confederations (Confcommercio, Confesercenti and Confapi).
At the initiative of AITI and some business associations, representatives of the public
administration and final users formed a Payment Services User Committee to jointly
examine impacts and needs in connection with SEPA.
Public administrations
The public administration is represented by the Ministry for the Economy and Finance and
the National Centre for Information Technology in Public Administration - CNIPA.
To examine the impact of SEPA on central government departments, a restricted working
group has been formed by the Ministry, the State Accounting Office, CNIPA, and Banca
d’Italia as State treasurer.
As for local government, there has been a joint study within the ABI working group on
Finance, IT and Local Government.
Consumers
Consumers are represented by the Association of Consumers.
The SEPA Consultation Forum
To ensure interaction between the banking system and the working groups on corporates, central
and local government, and consumers, the SEPA Consultation Forum has been created. The Forum
has begun to develop possible AOS, which will be subject to feasibility studies to supplement the
“basic” SEPA schemes.
2.2. The position of the various actors in the migration process
1. Banking system:
Italian banks are conducting technical, legal and commercial studies in view of the migration
to SEPA. In meetings they committed themselves to making basic products (credit transfers and
direct debits) available to customers for the January 2008 milestone. This commitment was
approved by the ABI Executive Committee and presented to the National Migration Committee
in December 2006 as ABI’s national plan for the banking system. They have also stressed
repeatedly that this decision, with the consequent deferral of a more sophisticated scheme to be
attained by developing AOS, depended mainly on the high costs in terms of human and financial
resources now borne by the banks for analysis, implementation and marketing of the new SEPA
instruments.
As to direct debits the banking industry (in line with the concerns of corporates, as set out
below) is concerned over the design of new instruments that are not competitive with current
services, i.e direct interbank direct debit (RID) and automated bank receipts (RI.BA.), originated
by cooperation between the banking system and the market (corporates) and endowed with
functions that fit Italian needs.
Against this background and in view of the position of the EPC as set out in its letter of 9
March (see section 2.1), in April the ABI Executive Committee resolved that ABI will continue
to urge banks to adapt their internal applications for handling a “basic” SEPA Direct Debit
product by January 2008. The Committee also decided to postpone any commitment to the
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generalized availability of the new direct debit scheme until the framework for transposition of
the PSD has been better defined and improvements to the scheme agreed to within the EPC.
The foregoing also safeguards the possibility of bilateral or multilateral interbank
agreements in being or to be concluded for the provision of such services (direct debits and
credit transfers).
2. Corporates
Italian businesses have expressed agreement and lively interest for the objectives of the SEPA
project, which will enhance transparency in bank-firm relations, increase competition thus lower the
costs to final users. While acknowledging the immediate benefit of standardization of payment
services, the corporates:
o note that the EPC Rulebooks mainly concern the interbank domain and stress that they will
only use the SEPA products to the extent that they place obligations on users, specified in
the contracts between banks and corporates. They recognize the key role of the Association
for Interbank Corporate Banking (CBI)1 in creating for corporates a propitious environment
for the design of advanced “delivery channel AOS”, which are essential to make SEPA
really advantageous for corporates. For corporates, CBI is the channel for linking the
various direct debit and payment procedures in bank-firm relations. However, corporates
consider that to date the approach has been mainly top-down and that the stakeholders in the
project need to be brought promptly into the development of AOS at the national level. The
corporates acknowledge the soundness of the CBI choices effected within the framework of
the CBI2 project and the adoption of standard XML ISO 20022;
o point out that if the benefits were solely cross-border, it should be taken into due
consideration that cross-border transactions account for just 3 per cent of the total and that
the Italian economy consists largely of small and medium-sized businesses that are not
especially interested in cross-border payments;
o specify that over the years Italy’s direct debits have acquired a great number of functions
that businesses have no intention of forgoing in making the transition to the new SEPA
instruments (e.g. the Electronic File Matching and Automated Bank Receipts procedures);
o reaffirm that AOS are essential to making the new instruments attractive, considering the
needs of corporates;
o hold that pricing, both of basic services and of future AOS, remains a crucial question.2
Corporates hope that the migration to SEPA may lead to a rationalization of the production
costs for payment services and a similar rationalization of prices to users. They cannot give
a definitive answer on the timing of the migration until they have an indication on this front.
1
CBI Service (Interbank Corporate Banking), set up in 1995 by the Italian Bankers’ Association (ABI), is a set of
standards and a model of communication between banks and firms, allowing companies to access all of their bank
accounts through single access point. CBI allows corporate customers of any size to connect electronically via a unique
front-end solution offered by one bank and to exchange financial messages (mostly credit transfers/direct debit orders
and cash management reports) with all the banks where the corporate accounts are held (Italian corporate customers
have an average of five different account-servicing banks).
2
It is emphasized that banks, in compliance with the general principles of competition, remain free to set their own
prices both for SEPA basic services and for AOS.
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3. Public administration
The public administration has shown interest in the project. SEPA represents an opportunity to
innovate, to optimize internal processes with a view to greater efficiency and automation.
Notwithstanding this favourable approach, however, there are also fears of:
־ resistance to changing established “behaviour”;
־ the costs of adopting new procedures;
־ lack of uniformity in terms of structures and processes in local units of the public
administration;
־ the possible impact on existing regulations.
4. Consumers
Consumers have voiced concern over the cost and the difficulty of using the new payment
instruments. They have shown full willingness to work together with the banking system on
communication and sensitization initiatives.
5. Merchants
Merchants have asked whether SEPA will bring real benefits, especially in efficiency. They are
interested, above all, in payment cards, and in particular in the possibility of centralized acquiring at
European level for the major retail chains, in the reduction of merchant fees, in the unbundling and
transparency in acquisition services, which are now frequently sold as “packages”.
6. Infrastructures
Italian infrastructure operators are working to provide the service of
transmission/reception/settlement of SEPA credit transfers starting in 2008. However, the choices
concerning the provision of clearing and settlement services for SEPA Direct Debits have not yet
been completely defined. But within the framework of the STEP2 EBA service, SEPA Direct
Debits will be active from 1 January 2008.
3. The National Migration Plan for Italy
Implementing SEPA means introducing the new SEPA Credit Transfer and Direct Debit
instruments, plus alignment with the frameworks envisaged for cards and cash. In the light of these
changes, Italy has made a number of choices concerning current payment instruments, specifying:
־ the instruments that will migrate according to the EPC milestones;
־ the instruments that will migrate later, which are now being analyzed;
־ the instruments that will not migrate.
The choices on all Italian domestic payment instruments are set forth in detail below.
3.1. Credit transfers
At present the domestic interbank procedures that handle the exchange and settlement of credit
transfers are structured according to the clearing and settlement system in which they operate.
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LOW-VALUE CREDIT TRANSFERS (“BON”) WITHIN THE INTERBANK DATA
TRANSMISSION NETWORK AND SETTLEMENT IN THE NATIONAL CLEARING
HOUSE (BI-COMP)
Domestic credit transfers up to €500,000 exchanged via the Interbank Data Transmission
Network (SITRAD) and settled in the retail sub-system of the National Clearing House. The
instructions for these credit transfers are transmitted on day D, with interbank settlement on day
D+1. Since 2003 this BON procedure has also been available for credit transfers coming from
other European banks, up to the ceiling for simplified balance-of-payments reporting (now
€12,500). Credit transfers executed via the BON procedure are non-urgent payments and for the
most part not for large amounts, essentially relating to commercial transactions.
LARGE-VALUE CREDIT TRANSFERS (“BIR”) HANDLED BY NATIONAL REAL-
TIME GROSS SETTLEMENT SYSTEM (BI-REL)
Domestic credit transfers of unlimited amount exchanged via SWIFT and settled through
New BI-REL, the gross settlement system. These credit transfers are essentially instantaneous,
the transmission of the instructions coinciding with the interbank settlement. Essentially these
are urgent commercial or financial payments. The BIR procedure is also used for the payment of
taxes collected to special Treasury accounts with Banca d’Italia.
CREDIT TRANSFERS (“BOE”) SETTLED VIA THE NATIONAL GROSS
SETTLEMENT SYSTEM (BI-REL)
Inward or outward cross-border credit transfers exchanged between Italian banks, of
unlimited amount. These credit transfers are exchanged via SWIFT between the Italian bank that
is corresponding with the foreign originator (or beneficiary) bank and the Italian beneficiary (or
originator) bank and settled through New BI-REL. These payments too are essentially
instantaneous, the transmission of the payment instructions coinciding with the interbank
settlement.
3.1.1 Adoption of basic SEPA framework starting in 2008
Ordinary domestic credit transfer (BON)
The features of the SEPA credit transfer are comparable to those of Italy’s present ordinary
domestic credit transfer (BON) for executing payments smaller than €500,000. Banking industry
studies indicate that the characteristics of BON closely resemble those described in the SEPA Credit
Transfer Rulebook. Banks that performed this analysis envisage a period of duality between BON
and the “basic” SEPA credit transfer, in order to ensure the efficiency of the new procedure and full
response by the market.
AOS for the SEPA credit transfer
A) Community AOS on Interbank Corporate Banking channel
SEPA CT: Development of a SEPA-CT-compliant path for the customer-to-bank domain.
The path will comply with the Credit Transfer Implementation Guidelines (to date, analysis
is based on version 2.2), thus permitting full, end-to-end automation of the procedure. The
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roll-out schedule should be ready by October 2007, consistent with the 1 January 2008
milestone; SEPA CT obviously cannot be fully operational before that date.
3.1.2 Payment services under study
Large-value domestic credit transfers (BIR)
Given the characteristics of this instrument and the infrastructure for exchange, no detailed
analysis of the instrument has been performed. On the face of it, no significant differences from the
SEPA instrument were observed, but the idea of migrating in 2008 was not considered, because the
EPC sees the SEPA credit transfer as suitable for ordinary, non-urgent payments, while the BIR
transfer has a very high service content (gross settlement in BI-REL, instant settlement, unlimited
amount).
At European level a scheme for urgent credit transfers has been developed. Originating within
the Euro Banking Association, it is a non-proprietary procedure, open to all SEPA banks and not
tied to any particular settlement channel, that guarantees intraday end-to-end handling of urgent
credit transfers (individual, not batch). Corporates are now assessing whether the features of the
scheme meet the business needs that are already being served today.
For the interbank handling, under SEPA standards, of urgent credit transfers now handled
domestically via BI-REL, we will have to wait for the adoption of SEPA schemes by TARGET2. In
any case, the prospect of SEPA handling of urgent transfers is strengthened by the PSD’s provision
of a default time for end-to-end execution of credit transfers of D+1 by 2012.
AOS for credit transfers
A) Interbank community AOS
o Fixed value-date for beneficiary: Study of the possibility of allowing the payment
originator to determine the value date for the beneficiary customer. This analysis could not
begin until the PSD was approved.
B) Interbank corporate banking community AOS
o Credit transfer at beneficiary’s initiative: This service allows the originator to specify the
banking coordinates for the debit but not to alter the amount. The time required to execution
depends on how long the executing banks take. The standard for the service, compliant with
the SEPA Credit Transfer Rulebook and the related implementation guidelines (version 2.2)
will be issued by July 2007.
o Execution report to originator and beneficiary: Report of the outcome of the credit
transfer, generated by the originator’s executing bank to the beneficiary of the payment, if
the originator so requests. The standard for the service, compliant with the SEPA Credit
Transfer Rulebook and the implementation guidelines (version 2.2) will be issued by June
2007.
o Credit report to originator: An execution message generated by the beneficiary or the
beneficiary’s bank and forwarded to the originator’s bank. Italian corporates requested the
introduction of this message service at the National Forum. The message is generated when
the account statement of all payments is received and provides the originator with
confirmation of the credit transfer. The banks will evaluate its feasibility in accordance with
existing interbank procedures.
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3.1.3 Non-migrating payment services
Cross-border credit transfer
The cross-border credit transfer is a payment instrument that entails an exchange of information and
funds between two Italian banks, one as the correspondent of the foreign bank and one holding the
account of the customer (who may be resident or non-resident) in Italy. This service will not
migrate, because it will be used for payments to and from countries not belonging to SEPA.
3.2 Direct debits
The Italian banking system’s direct debits are highly customized and so far have satisfied the
market’s needs, which go beyond the simple assignment of debits to the debtor’s current account. In
this light, the migration of a variety of national direct debits to the SEPA Direct Debit scheme
would be difficult. The studies described below emphasized how complex the process is.
The main direct debits, which are under study by the relevant working group, are the following:
MAV – Payment on notice and bank form
Credits are collected by notifying the debtor to pay – at any bank – using a special form sent to
him by the creditor’s bank.
Ri.Ba. – Automated Bank Receipt
Direct debit via electronic receipt issued by the creditor.
RID – Direct Interbank Debit
Direct debit via permanent debit order issued by the debtor
o AEA – Electronic database alignment
Known as AEA (Italian acronym for Allineamento Elettronico Archivi), it is a computerized
interbank procedure in support of RID for the electronic management of various types of
mandates.
3.2.1. Direct debits that will migrate starting in 2008
In close cooperation with stakeholders, in 2006 the banking system began analyses towards the
migration of the RID service to SEPA Direct Debit standards starting in 2008. The studies
conducted in the course of 2007 in terms of processes and standards were incomplete owing to the
lack of the final text of the PSD.
Accordingly it is essential, as the Eurosystem has noted, that with the adoption of the Directive by
the European Parliament, the banking industry and all the other stakeholders maintain momentum
and intensify preparation for the launch of SEPA by 1 January 2008 and its subsequent successful
and timely implementation.
As a result of the delay in passage of the Directive it is possible that, without prejudice to
the 1 January 2008 date for the launch and the technical implementation of banking
applications, the SEPA Direct Debit instrument will be made fully available at a later stage, in
order, among other things, to ensure its maximum effectiveness and response to stakeholders’
needs. Further, detailed analysis will be coinducted after the drafting of a new version of the
EPC documents on the direct debit instrument (scheduled for release in June 2007).
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Banks involved in the studies envisage a period of dual use between current instruments and the
SEPA direct debits, to make things easier for market participants.
RID - Interbank direct debit
The SEPA Direct Debit has implementation rules (both procedural and on messaging) that are
significantly different from current Italian direct debits. The studies conducted focus mainly on the
RID service, whose functional characteristics make it most comparable to the pan-European
instrument. The main differences are the following:
Information exchanged: RID requires only the data necessary to execute the debit; SEPA DD
requires a reference to the mandate giving rise to the debit/credit relationship.
Procedure for mandate management: Today, the mandate is provided to the creditor or to its
bank on a standard (paper) form. The SEPA scheme does not provide for such flexibility; the debit
mandate is handled exclusively by the creditor.
Mandate form: The RID mandate is strictly paper-based, while SEPA Direct Debit provides for
the possibility of an electronic mandate.
AEA - Electronic Database Alignment: In Italy this service is present and used, managing the
information on the mandate through a special electronic interbank procedure. In SEPA the data on
the mandate are transmitted by the creditor to its bank together with the request for direct debit.
Advance notice: In both RID and SEPA Direct Debit the creditor undertakes to send notice to the
debtor in advance of the direct debit date. Under SEPA this notice must be made at least 14 days in
advance (unless a different agreement between the parties exists).
Types of instrument: Italy has three different types of RID, depending on the user’s functional
requirements. SEPA Direct Debit differentiates only between one-off and recurrent debits.
Debit rejection: RID now provides that the debtor may reject the debit prior to the direct debit due
date or within five working days thereafter, depending on the type of RID (these deadlines do not
take account of the obligations that will stem from transposition of the PSD). SEPA Direct Debit
provides that the debtor may reject the debt within six weeks after the debit (again, this does not
take account of the PSD, which provides for a period of eight weeks for rejection).
Term for irrevocability: In the RID procedure, once the term for sending any unpaid items has
elapsed, the interbank settlement is presumed to have taken place (term for irrevocability). The
SEPA Direct Debit procedure sets a mandatory term for notification of an unpaid item, even if the
presumption of payment is linked to much longer terms for non-rejection.
3.2.2 Direct debit services under study
AOS RID – Direct Debit
A) Interbank community AOS
o Electronic Database Alignment (AEA): Studies on the possibility of creating a
service comparable, in terms of functions, to the existing interbank service in support
of the RID procedure, permitting central electronic management of the various types
of RID mandates.
o “Fast” direct debit: Study on the possibility of giving SEPA Direct Debit the
specific function of Italy’s fast RID procedure.
B) Interbank corporate banking community AOS
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o SEPA DD: Development of a SEPA-DD initiation and reporting messages for the customer-
to-bank / bank-to-customer domain. Messages will comply with the SEPA Direct Debit
Implementation Guidelines (to date, analysis is based on version 2.2).
RiBa - Automated Bank Receipt: non-preauthorized, one-off SEPA Direct Debit
To date, the migration of Ri.Ba has only been studied in relation to the likely impact of the PSD.
Detailed analysis has not been conducted, because the EPC documentation describing SEPA Direct
Debit from the B2B perspective is not yet officially available. Analysis has been deferred until this
information is available.
3.2.3 Non-migrating direct debit services
MAV - Payment on notice and bank form
These instruments are not among the most important direct debit services for the business
market, and their features are clearly at odds with the requirements of the latest version (2.2) of the
SEPA DD Rulebook. Italy has therefore not undertaken detailed studies or traced a migration path
for them.
3.3. AOS under study
Some AOS are not linked either to direct debits or to credit transfers, i.e. are independent of the
instrument.
A) Interbank community AOS
o IBAN/UEI check: The Rulebooks provide that funds transfers be based on IBAN
only; Italian corporates, however, call for a check of consistency between IBAN and
a Unique Entity Identifier (in Italy, the tax number), which is now under study.
o Remittance Information: Studies on possible ways of organising remittance
information, now under way at EPC and the European Association of Corporate
Treasurers, that take account of SEPA rules for interbank forms (140-character
limit).
B) Delivery channel AOS (Interbank corporate banking – CBI)
o Invoice financing: Service that will permit “zero latency” transmission of invoices and
possibility of automatic activation of financing and payment procedures.
3.4. Credit and debit cards
The implementation of SEPA as regards payment cards will come via application and
enforcement of the EPC’s SEPA Card Framework (SCF), which lays down common principles,
rules and practices that banks and scheme operators will have to follow. The framework sets out
three possible macro-scenarios for the future of domestic payment schemes:
־Option 1: select one (or more) international schemes to replace the current national scheme(s)
– once the former have become SCF compliant;
־Option 2: act in such a way as to evolve national schemes so that they become SCF compliant;
amongst other implementation options, national-based schemes, once they have become SCF
compliant, may e.g. extend their operations to the entire SEPA, or may enter into alliances
with other national-based SCF compliant schemes. Such alliances may also involve national-
based and international schemes, provided that they have both become SCF compliant;
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־Option 3: co-brand cards with both a national and an international schemes – provided that
they have both become SCF compliant.
Italy, through CO.GE.BAN (which manages the Bancomat debit card brand), favours the co-
branding option (option3) as the best for the Italian system. CO.GE.BAN is also participating in the
work on the “Pandomestic” Scheme (option 2), which will be called the “Euro Alliance of
Payment Schemes” (EAPS). The key features are reported as follows:
־ EAPS arises as a federation of current domestic schemes. Banks in countries lacking such
schemes can therefore join directly;
־ the business model is multilateral, with a common rulebook for all participants;
־ an acceptance brand will be created alongside the domestic scheme brand, permitting
customers to use it abroad;
־ interbank fees will be set in line with those of international schemes;
־ the governance structure will be a cooperative, based on associative principles for
membership, contributions and voting;
־ the costs of the governance structure will be pro rated according to participants’ market
shares; no transaction or card fees will be charged;
־ no advertising campaign is foreseen, as the brand will rely on the recognition of the
individual domestic schemes;
־ standards will be those currently under study by the EPC in order to minimize investment by
using the same standards banks will have to observe for SEPA itself;
־ co-branding with international schemes and with other commercial partners will be possible.
Some banks have already initiated bilateral agreements to test the functioning of the
“pandomestic” scheme.
Certification activities of cards, processes, ATM and POS terminals have already begun, in
order to reach the EPC milestones on time. As to the requirement for payment schemes to introduce,
by 1 January 2008, rules and other incentives for migration to EMV, in July 2006 the CO.GE.BAN
Council decided to institute a liability shift; that is, for chip card transactions on non-EMV
terminals, liability for fraud will lie with the acquirer bank, the scheme providing no form of
guarantee. In order to offer an incentive for the migration of cards and terminals to chip technology,
appropriate arrangements for sharing costs related to fraud among participants have been
introduced, in particular:
־ as of 1 January 2007, a system of guarantees covering chip card transactions on chip
terminals;
־ also as of 1 January 2007, a second, parallel guarantee system (that will remain in place until
31 December 2007), for transactions using magnetic stripe cards. In the course of the year
the need for an extension of that deadline will be evaluated.
The EPC is continuing work to define interoperability standards in the four scheme domains:
cardholders-to-terminal; type approval, terminal-to-acquirer interface, and acquirer-to-issuer.
3.5 Cash
The institution of the Single Euro Cash Area (SECA) will entail profound changes in the
procedures and practices of NCBs, banks, and market agents in handling cash, which will have to
comply with two key documents:
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the Recycling Framework, to guarantee the genuineness and fitness of the banknotes in
circulation through a common policy on recycling
the SECA Framework, a common set of rules and best practices for banks in distributing
and recycling cash within the euro area.
3.5.1. The Recycling Framework
National central banks pledged to implement the principles of the Recycling Framework by the
end of 2006. Such a framework allows for a transitional period ending at the end of 2007 so that
the various stakeholders can adapt their procedures and equipment.
In its 2006 report on progress with the Framework, the ECB Governing Council noted that in six
euro-area countries, Italy among them, it would be necessary to extend the transitional period so
that the market – suppliers and outsourcers – could adapt fully and efficiently to the changes in
sorting equipment and operating procedures. The Governing Council accordingly approved the
extension of the transitional period through the end of 2010.
In Italy, work on the Framework is at an advanced stage:
־ joint testing by Banca d’Italia and the ECB began in 2006 to check whether Italy’s counting
and sorting equipment met the Framework’s requirements;
־ statistical data on cash recycling, supplied to Banca d’Italia by banks and professional cash
handlers, were fully phased in at the start of 2007.
3.5.2. The SECA Framework
The Italian banking system has undertaken to comply with the requirements of the SECA
Framework by 1 January 2008. In particular:
־ Standardization and automation of information. Analyses were conducted by the
banking industry in cooperation with Banca d’Italia in 2006 to design a system of
standardized information, managed electronically and certified, for banknote deposits and
withdrawals. This will replace the current method of telephone calls and faxes.
In addition, the Eurosystem and the ECB have resolved that starting in June 2007 remote
access to the cash services of the national central bank must be available in all euro-area
member states. Banks, in turn, must be compliant with the rules for remote access to the cash
services of the NCB at which they deposit and withdraw cash. This will enable NCBs to
provide cross-border services, i.e. provisioning and distributing cash also to banks not within
their jurisdiction (non-resident banks).
־ Harmonization of packaging of coins and notes within the SEPA area. In June 2006 Italy
specified two possible standards, now being evaluated by the ECB. The Eurosystem will
specify a limited number of standards for the packaging of free of charge cash services.
NCBs can use additional packaging formats if needed at national level.
־ Optimization of the distribution chain. The Italian banking industry is reviewing its cash
processing chain for better efficiency.
־ Territorial coverage of NCB branches. Banca d’Italia has begun studies.
־ Business hours of NCBs to be uniform and consistent with the needs of banks and
professional cash handlers. Activities toward this end depend heavily on the EPC’s future
decisions and the position of Banca d’Italia. The ECB Governing Council approved (26
September 2002) a common approach to business hours. A common window of at least 6
15
hours a day for deposits and withdrawals of banknotes must be observed by at least some
units of the national central bank, such as branches, headquarters and cash centres.
The withdrawal of coins is not specified in the SECA Framework, but Italian national planning
considers it as one of the activities necessary for implementation of SECA. With a view to the
harmonization of the legal framework and operational conditions for euro-area NCBs, it has been
noted that Italy is now the only country in which the central bank does not withdraw coins. The
ECB Governing Council has resolved that all euro-area NCBs must accept deposits of coins from
customer banks starting at the end of 2007.
3.6 Communication and training: SEPA Project support
The banking system has begun communication and training programmes. ABI, with the
participation of Bancaria Editrice and ABI Formazione, has developed a number of activities and
instruments to satisfy the various needs of the banking system and individual stakeholders in order
to (i) ensure the greatest possible consistency with EPC and ECB guidelines; (ii) coordinate
integrated communication/training at central level ; and (iii) produce the best possible results for
banks. The model will be specified in the form of a number of ad hoc initiatives in the course of
2007.
The main initiatives already taken by the Italian Bankers’ Association (ABI) include:
SEPA Blue Book: For this far-reaching and complex project, ABI has prepared a paper-
based and online communication and support tool for banks, providing and explaining the
necessary information on a periodic basis. The Blue Book contains the relevant
documentation of the EPC, the Eurosystem and ABI’s own working groups, as well as the
most important communications and special documents drafted to clarify and summarize the
most significant issues and procedures underlying the SEPA project.
SEPA website: For quick communication with banks and other stakeholders and easier
coordination of the banking system in advancing toward SEPA, ABI is creating a website
dedicated to the Project. The idea is to create a common platform, an “institutional space”
for the Project, by means of which to provide all users with the key information and
maximize the efficiency of the numerous activities of coordination and monitoring.
So far, it must be noted that knowledge of the SEPA project remains largely limited to the
banking system. Targeted communication and training are still needed to bring all the stakeholders
into the process. SEPA’s success depends to a great extent on the involvement of all the relevant
stakeholder groups. The issue has been taken up by the European Central Bank, which together with
the EPC and the Commission, has decided on a joint communication strategy for SEPA. The
Eurosystem is defining specific lines of action, calling for the involvement of national central
banks. Each country will have to develop its own communication plan based on cooperation
between the stakeholder representatives in the National Migration Committees.
3.7. Further study on the Plan
3.7.1. IBAN – International Bank Account Number
Given the importance for SEPA of straight through processing (STP), IBAN and BIC will serve
as unique identifier of the current account and the bank for all SEPA transactions. IBAN, as we
know, is based on the ISO 13616 and ECBS EBS204 standards. The IBAN structure adopted by
Italian banks is:
• 2 characters for country code (IT)
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• 2 numbers for international code
• 1 letter for national control code (CIN code)
• 5 numbers for bank code (ABI code)
• 5 numbers for branch code (CAB code)
• 12 letters or numbers for current account number.
The BIC is based on the ISO 9362 standard; it is the routing code used by SWIFT.
3.7.1.1. IBAN Strategy
The Italian banking system agrees with the EPC’s medium-term IBAN strategy of making the
Bank Identifier Code (BIC) and the International Bank Account Number (IBAN) mandatory for the
interbank domain.3 Whether or not to require customers to supply the BIC or to offer a service of
deriving BIC from IBAN is a matter for competition between banks.
Following its “Statement of principles and functional requirements for an IBAN/BIC
Database,”4 the EPC defined the basic functional requirements for national IBAN/BIC databases,
through which the BIC corresponding to the national IBAN can be derived.
In the long term, depending on the situation produced by the above-mentioned IBAN Strategy,
the EPC and the member countries, in agreement with the ECB, may reconsider this approach,
weighing the need to simplify the structure of IBAN to overcome differences between national
identifiers within SEPA. The Italian banking industry has long sustained and sought to facilitate the
path of integration of the domestic payment system within the SEPA framework, including the use
of IBAN to identify current accounts. Years ago Italian banks applied the IBAN standard adopted
for uniform international identification of current account numbers. Since then, therefore, there has
been a period of duality: IBAN is mandatory to identify the beneficiary of cross-border payments
and can also be used in place of national banking coordinates for domestic credit transfers.
As the SEPA project developed, it became necessary to plan to drop the national “banking
coordinates” standard and make IBAN the unique standard, for domestic transfers as well. The plan
calls for making IBAN exclusive in January 2008. It was seen as advisable that this significant
change coincide with the initial availability of SEPA credit transfer and direct debit services and
products. ABI Circular “Serie Tecnica”, No. 35, dated 31 July 2006, notified banks that starting 1
January 2008:
• IBAN will be the unique, exclusive standard used to identify current accounts in the execution
of domestic payments (credit transfers and direct debits), regardless of their amount, consistent
with the current European rules for cross-border payments;
• the “old” national banking coordinates can no longer be used for that purpose, and those
standards (CIN, ABI code, CAB code, account number) remain valid only for determining the
Basic Bank Account Number (BBAN) incorporated into the IBAN code.
To facilitate the changeover to IBAN as exclusive standard for the identification of current
accounts, technical measures were designed with the direct involvement of corporates, and
changes to the interbank rules were introduced.
The solutions envisaged, described concisely below, are:
1. IBAN Electronic Database Alignment (AEA) of major originators of credit transfers on the
domestic scheme;
3
For details on the EPC strategy, see “The SEPA IBAN Strategy”, approved by the plenary meeting of the EPC in
September 2006.
4
Approved by the EPC in plenary session 14 March 2007.
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2. an interbank penalty charged to the originator’s bank and paid to the beneficiary’s bank for
credit transfers on which the IBAN is lacking or formally inexact.
IBAN Electronic database alignment
The procedure is designed, with a view to the changeover to IBAN on 1 January 2008, for the
massive alignment of the databases of corporates (as originators of payments) with those of banks
as regards the banking coordinates (IBAN) of credit transfer beneficiaries. Those using the
procedure can effect direct electronic communication, via a “reference bank”, with the banks at
which the beneficiaries’ accounts are held, transmitting and receiving the IBAN data of the payment
beneficiaries. Before this procedure goes operational, however, timely and detailed information will
have to be supplied to all those involved. The system re-uses the same application and messages
used for the management of direct debit mandates.
On 10 April 2007, in response to a request for an opinion submitted by ABI in 2006, the data
protection commission acknowledged the banking system’s intention to create the procedure, with
the characteristics described.
The delivery of the procedure for corporates and banks is scheduled for the fourth quarter of
2007.
Interbank penalty charged to the originator bank, in favour of beneficiary bank, for credit
transfers using incorrect IBAN coordinates
It stands confirmed that the existing interbank penalty fee for credit transfers lacking complete
bank coordinates should be retained and extended to all credit transfers on which the IBAN
coordinates are lacking or not formally correct. The application of this disincentive will be
consistent with the timeline for the general switch to IBAN, taking account of the situation that
emerges from the IBAN electronic database alignment described above.
3.7.2. Focus on the analyses of non-bank stakeholders
3.7.2.1. Corporates
Within the SEPA consultation forum, corporates have worked together with the banking system
to define the Additional Optional Services (See section 2.2, “The position of the various actors in
the migration process on corporates”, section 4.1 “Delay and problems in transposing the Payment
Services Directive” ,and section 4.2 ”SEPA and reporting requirements”).
3.7.2.2. Central government departments
The banking system and the institutions representing the central government have begun a
preliminary mapping of the main categories of services now used by central government
departments. The SEPA consultation forum for central government has named the following as
priority areas in terms of diffusion and payment volumes:
־ Payment orders
־ Public employee salaries and pensions
־ Social security payments
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־ Cassa Depositi e Prestiti5 payments
As to the procedure for payments to the central Treasury via credit transfer, under the
Regulation published in the Official Journal of 21.12.2006 this service will be SEPA-compliant
and delivered in June 2007.
3.7.2.3. Local government
Analysis of local government procedures and the methodology adopted are designed to permit
the delivery of SEPA compliant direct debits and credit transfers, using data transmitted by the
national G2B2G (government-to-bank-to-government) electronic payment/debit initiation and
reporting procedure (OIL). OIL is an instrument whereby payment debit orders between
governmental agencies and the treasurer/cashier banks are transmitted using standard XML
messages. The instrument is intended to eliminate the paper based transactions between government
bodies and banks.
The analysis performed to date consists in comparing the information in the OIL messages with
that called for in the SEPA Implementation Guidelines for credit transfers and direct debits.
Specifically, to determine the main needs for SEPA-compliance of the OIL messages, the work
group considered the mandatory data that must be present in an SEPA direct debit or credit transfer
when it reaches the bank.
This analysis specified the data that are not now present within the OIL messages but that are
required to activate direct debits or credit transfers under SEPA schemes. The results have
highlighted the need to adapt the OIL messages to align them with EPC requirements; the migration
procedure is now under discussion by the banking system working groups. Two different
approaches to achieving compliance with the EPC requirements for the government-to-bank domain
have emerged:
־ minimum adjustment of the present OIL messages to SEPA requirements by modifying the
current procedure. This would leave unchanged the present practice whereby the direct debit
order requires two different information flows (one for internal purposes of the
governmental agency and one for the bank);
and
־ more radical adjustment of the present OIL messages to SEPA requirements, under which
the system – banks and local government – would ensure that the OIL messages, and in
particular the information flow needed for internal purposes of the governmental agency,
contains also the data necessary to the treasurer bank to generate a direct debit. This
solution, though more costly, would encourage the diffusion of more advanced direct debits.
The possibility of registering under ISO 20022 a message for government-to-bank-to-government
payment/debit initiation and reporting is under evaluation. This possibility will be analysed in more
detail at a later stage after the adjustment of the present OIL messages to SEPA requirements, also
in order to improve commercial and financial relationships between government agencies and
corporates (as providers of goods and services for government agencies).
5
The Cassa Depositi e Prestiti mission is to foster the development of public investment, local utility infrastructure
works and major public works of national interest, ensuring an adequate return for its shareholders while preserving its
long-term financial and economic balance.
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3.7.2.4. Consumers
The Association of Consumers has endorsed the planning of a campaign of communication and
sensitization in agreement with the banking industry. Consumers’ interest focuses on credit and
debit cards, which are the instruments that have the greatest impact on final users.
3.7.2.5. Infrastructure
Italian retail payment infrastructures affected by the migration consist of the three operators
assigned to perform activities preliminary to settlement via the BI-COMP clearing system
(SIA/SSB, Seceti and ICCREA) and BI-COMP itself. They are working to be able to provide SEPA
credit transfer transmission/reception/settlement starting in January 2008. The choices on provision
of SEPA Direct Debit clearing and settlement services have not yet been completely defined. The
plan is for a period of duality between SEPA services and current existing services.
Seceti, ICCREA and SIA-SSB all plan to become SEPA-compliant CSMs, directly providing
exchange services and settling via: a) BI-COMP; b) Step2/EURO1.
As operator of BI-COMP, Banca d’Italia will develop together with the clearing infrastructure
operators standards of interoperability – under the rules laid down in the EACHA framework – to
ensure that the banks participating in all other SEPA-compliant CSMs can be reached.
The infrastructures should always transmit both the optional fields necessary for the AOS
(“white”) and the core set of SEPA fields (“yellow”) to facilitate development of the AOS and
reduce the risk of market fragmentation.
In addition to these Italian operators there is EBA Clearing, which is preparing the STEP2
platform -- operational since 2003 for cross-border credit transfers consistent with the functions
envisaged by the Credeuro Convention -- for provision starting in January 2008 of SEPA credit
transfers and direct debits under the EPC Rulebooks. At first these services will settle via EURO1,
but a feasibility study is under way to guarantee the possibility of settling via TARGET2 when all
countries have migrated to the new platform.
In addition, in November 2006 the six largest Italian banks have migrated, for their domestic
credit transfers, to the STEP2 platform (the Italian Credit Transfer (ICT) service). This service was
developed, like the core functions of STEP2, with a view to convergence to SEPA Credit Transfers
(which will be consistent with the decisions to be taken by the Italian banking system). It will be
updated to ISO 20022 message standards in the course of 2007.
4. Open questions and problems
There are a number of other factors and situations that could have an impact on planning
outcomes.
4.1. Delay and problems in transposing the Payment Services Directive
According to the EPC, the implementation of the SEPA Direct Debit scheme is connected with
transposition of the Directive, recently approved by the European Parliament, by all SEPA member
states. Though there are no insurmountable legal obstacles to the implementation of the SEPA
Direct Debit, there is nevertheless a risk of delay in the transposition of the entire Directive (hence
of the parts complementary to SEPA) owing to the greater complexity of introducing the Title II
norms (rules governing payment institutions) at national level.
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4.2. SEPA and reporting requirements
Stakeholders – banks and corporates in particular – have pointed out that in Italy the present
reporting procedures for balance-of-payments statistics and for purposes of fiscal monitoring and
combating money laundering apply to all payments larger than €12,500, which conflicts with what
the European Commission has called for in the Payment Services Directive and the EPC Rulebooks
for SEPA credit transfers and direct debits. Although it is expected that the relevant authorities will
raise the threshold to €50,000 as of 1 January 2008, the stakeholders are concerned over the rules
differences that would remain in Italy, such as to adversely affect the possibility of fully automated
handling of transactions for customers’ account. Raising the threshold, in fact, would not eliminate
a competitive disadvantage vis-à-vis other SEPA countries, where banks are not subject to these
reporting requirements.
4.3 B2B direct debits
Italian stakeholders have asked that the SEPA instruments introduced at national level, possibly
supplemented with appropriate AOS, be such as to satisfy the needs of end users and not in any way
diminish current service levels. This is especially important for direct debit services, in whose
regard for some time now Italian banks and corporates, in their respective areas of competence,
have been promoting additional functions over and above those specified by the EPC.
4.4. SEPA card framework – Interoperability standards
The definition of standards for the various domains of interoperability – card-to-terminal,
terminal-to-acquirer, acquirer-to-issuer, and type approval – is necessary to the migration of
domestic payment schemes to the SEPA scheme. It is essential that these standards be defined in
time for domestic payment schemes and banks to make their strategic choices in a framework of
less uncertainty. To this end there must be sufficient participation of the Italian banking community
in the international working groups on these activities.
4.5. Defining AOS
The process of deciding which additional optional services to offer in the various countries has
been set in motion. Italy is interested in full transparency in the development of community AOS to
ensure a level playing field and the harmonization of the market at SEPA level, to prevent the
uncontrolled proliferation of similar AOS.
CBI (Interbank Corporate Banking), which for many Italian corporates is the entry point into
SEPA, has developed technological and organizational arrangements consistent with SEPA. The
Italian banks’ investment in this service will be further enhanced from the SEPA perspective. The
involvement of non-bank stakeholders (above all, corporates) can still be improved by tightening
the liaison between the working groups on the interbank payment instruments, CBI, and
stakeholders.
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COGEBAN is the Italian association formed by ABI in order to enhance the development of
payment cards within the Italian territory.
Therefore, COGEBAN sets out the rules of the national card payment scheme and aims at
developing BANCOMAT/PagoBANCOMAT card transactions, ensuring, in accordance with the
needs and expectations of clients (both merchants and private citizens), high safety and quality
levels, through the definition and management of specific rules to which participant banks must
comply to.
In order to improve its products and their usability, COGEBAN carries out several activities, such
as:
- setting out the necessary provisions to ensure that every BANCOMAT/PagoBANCOMAT
card is universally accepted within the Italian territory to withdraw cash and make payments;
- defining multilateral interchange fees for the BANCOMAT/PagoBANCOMAT products;
- guiding the Scheme towards a Single Euro Payment Area (SEPA) compliance;
- approval of all card layouts, including monitoring of the issuing phase;
- preventing frauds through a specific entity (“Presidio per la sicurezza monetica –
COGEBAN”);
- a geo-referenced ATM finder, named FARO, which gives real-time information to clients on
functioning ATMs across the Italian territory.
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The CBI Service
1. The CBI Service and the ACBI
CBI Service (Interbank Corporate Banking), set up in 1995 by the Italian Bankers’ Association
(ABI), is a set of standards and a model of communication between banks and corporate, allowing
companies to access all of their bank accounts through one single access point. CBI allows
corporate customers of any size to connect electronically via a unique front-end solution offered by
one bank and to exchange financial messages (mostly credit transfers/direct debit orders and cash
management reports) with all the banks wherein their accounts are held (Italian corporates rely upon
an average number of five different account-servicing banks).
Receiver Bank
Executing Bank
C&S
Systems
Receiver Bank
Company
Executing Bank
Access Bank
Receiver Bank
Executing Bank
Figure 1: Operational model of CBI Service
The CBI infrastructure was constituted with the aim to support the financial relationship between
Italian corporate and banks.
The main service categories offered by banks to their clients through CBI are:
o Pre-authorized and non pre-authorized debts
o Payment services
o Reporting services
o Market place operations
o Tax payments (F24)
23
In 2001 the CBI Association (ACBI) was constituted with the aim to coordinate all the players
involved, not interfering with the competitive issues of each bank. The purpose of ACBI is to
guarantee the efficiency and the effectiveness of CBI, being responsible for standard setting,
architecture evolution, new services definition and governance. It operates through specific working
groups composed of experts designated by the associated banks and is governed by the board of
CBI, composed of representatives of 15 different banks (all major Italian banks are included).
Nearly 690 Italian banks (which represent 90% of the overall banking community) participate in the
CBI system, which is used by over 600,000 companies (mainly SMEs).
CBI is a payment initiation network. All the payment orders sent/received throughout the CBI
network are based on message standard used by clearing systems, for simplifying the execution of
payment order received by the executing bank.
In Italy the CBI standards represent a key reference for both multibanking and home banking
solutions, thus for every corporate that holds an electronic connection with its bank (e.g. Internet
banking).
2. New CBI infrastructure
At the end of last February 2007, the ACBI launched a new CBI infrastructure, based on the XML
standards, which is able to support new services for corporate. The most important drives of ACBI
new technical architecture are:
• enabling direct co-operation (“peer-to-peer”) among different players (e.g., end users and
banks)
• supporting automatic reconciliation through structure remittance information
• supporting message syntax able to carry “structured” and “non-structured” information (e.g.
binary images, ...)
• enabling end-to-end security data interchange between the parties
• supporting digital signature for legally binding document exchange
• supporting real time/near time execution of services
• supporting the development of services that also involve non-traditional players
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As showed below, the new CBI infrastructure enables end-to-end communications between banks
and/or corporate, in order to support transmission protocols such as file transfer, synchronous and
asynchronous instruction exchange. Each company, through its access bank, will be able to send
and receive credit transfer, direct debit and, thanks to new CBI document-exchange services,
invoices and unstructured documents.
In fact, new CBI architecture and the new service features will also enable banks to offer electronic
invoicing transmission which is compliant to EU regulation (number and type of information), and
has a suitable standard communication.
Payment Initiation Layer Clearing and settlement
Buyer Access Bank CBI Architecture Executing Other Banks
of Buyer Bank of Buyer
Clearing
and
settlement
SEPA
Seller Access Bank of Executing
the Seller Bank of Seller
CBI Message standards are based on the
CBI Message standards used by clearing and settlement
Standards circuits (SWIFT, ISO20022, SEPA etc.)
Figure 2: CBI compliance with international standards
Throughout the new CBI architecture corporate clients will be able to exchange both structured (e.g.
XML invoice) and unstructured (e.g. pdf files) invoices and documents (end-to-end interchange via
their access banks).
The foundation for the definition of the message standards have been defined by analyzing the most
significant “invoice standards”, such as ebXML, Visa, EDIFACT, SwissDigin, Finvoice etc.
Thanks to new CBI electronic invoice service, the new CBI architecture will be considered as
another way to send and receive both electronic invoices and other electronic documents.
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The communication on CBI network is based on CBI XML standard messages and can support “file
transfer” and “real time” messages exchange.
The CBI standards will be able to support the European Payment Council SEPA and ISO 20022
standards. Currently ACBI Working Groups are focused on the definition of the Credit Transfer
XML messages for the Customer-to-Bank Area, according to the SEPA requirements and Italian
corporate needs.
In fact, EPC defines rules, procedures and standards to be adopted in the interbank area. These
guidelines, to implement the SEPA messages, have been produced basing on the ISO 20022
standards. In the same way, regarding to Customer-to-Bank Area, EPC recommends the use of
XML-based ISO standards.
Standard messages in the “initiation” layer of CBI area will grant the alignment with the following
message schemes:
• CustomerCreditTransferInitiation
• CustomerDirectDebitInitiation
Thanks to its active role in the international scenario, ACBI has undertaken several initiatives at a
cross-border level, such as:
• UN/Cefact TBG5 (permanent member);
• Trade Services SEG (Standard Evaluation Group) under ISO 20022 (permanent member);
• Management of registration process for new CBI service “Invoice financing” under ISO
20022 Repository;
• ISO 20022 Registration Management Group (permanent member);
• CEN/ISSS (Workshop e-Invoicing), ETSI, EPC/OITS/SPTF (active participation);
• “Informal e-Invoicing Task Force” promoted by the EC (permanent member and
willingness of taking part in the next Steering Committee).
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