NACE Rev. 2.1 — activity-code migration for payments firms

Between January 2025 and January 2027, the activity code on almost every European business customer changes, and in most cases the customer does nothing. NACE Rev. 2.1, the revised EU classification of economic activities, replaces the 2008 NACE Rev. 2 in statistics, and the national classifications built on it follow on their own dates. Company registers rewrite the codes automatically. Banks switched their ECB and EBA reporting to the new list from 1 January 2026. A payments firm that keys risk tiers, prohibited-activity lists or merchant categories on an activity code faces a data migration, whether or not it has scheduled one.

1. What NACE Rev. 2.1 is, legally

NACE is set by Regulation (EC) No 1893/2006. Commission Delegated Regulation (EU) 2023/137, adopted in October 2022 and in force since 9 February 2023, replaces its Annex I with the revised classification. Article 2 applies it to data sent to Eurostat from 1 January 2025, with later start dates by statistical domain. Business statistics moved in 2025 and 2026, and some social statistics run to 2031. National accounts switch in September 2029.

The EU layer is harmonised down to four digits: section, division, group and class. Member states may add national detail beneath it. That is why national versions run to five or six digits. It is also why a four-digit NACE code and a national five-digit code for the same business are both correct.

2. What moved — the changes that reach a payments firm

Most codes only gained detail. A handful of structural changes matter for anyone who classifies merchants or business customers.

• Sections were relabelled. The old information and communication section was split. Section J now covers publishing, broadcasting and content production. A new section K covers telecommunications, computer programming, computing infrastructure and other information services. Financial and insurance activities moved to section L, keeping divisions 64 to 66, and real estate moved to section M. A rule written as “section K = finance” now selects IT firms.
• Retail lost its sales channel. The distinction between shop, internet, market-stall and mail-order retail is gone, and retail is classified by what is sold. An “internet retail” code no longer exists to key an e-commerce policy on.
• Intermediation got its own classes. Platforms that match buyers and sellers for a fee, without owning the goods, have dedicated intermediation classes in almost every section. Class 47.91 covers intermediation for non-specialised retail. For a payments firm this is the most useful change: marketplaces become distinguishable from merchants of record.
• Some activities changed section. Germany’s statistical offices give the example of property developers moving out of construction into real estate. Short-term rentals of under a year move to accommodation in division 55.

3. The national versions, and when each register switched

So the same customer base holds three vintages of code at once. Italy and the Netherlands are already on the new list. Belgium is on it, with a 2025–26 clean-up. France switches in 2027. Anything captured before these dates is in a vocabulary the register no longer issues.

4. Bank and statistical reporting switched on 1 January 2026

The Joint Bank Reporting Committee advised on 30 June 2025 that NACE Rev. 2.1 be introduced across the European banking frameworks at the same time. The ECB and the EBA confirmed they would follow the advice. Banks reporting under ECB regulations or the EBA supervisory framework apply NACE Rev. 2.1 from 1 January 2026. Any report with a later reference date uses the new classification, and amounts are calculated under it rather than converted back.

The frameworks named include AnaCredit counterparty data, FINREP templates F 06.01 and F 20.07.1, large-exposures template C 27.00, credit-risk supervisory benchmarking and Pillar 3 disclosures. While the EBA template labels still carry the old codes, amounts under the new sections J and K go together into the old J row. Financial counterparties coded L64, L65 and L66 go into K64, K65 and K66. The ECB’s AnaCredit Q&A sets the switch: NACE Rev. 2 applies up to the reference date of 31 December 2025, and NACE Rev. 2.1 from 31 January 2026, with no parallel reporting.

The JBRC advice asks national central banks to follow the same timeline for national collections that use NACE. Any national statistical return with an activity breakdown should be checked for the version it now expects. Our AnaCredit submission guide covers who reports.

5. Where activity codes live inside a payments firm

Before migrating, list every place a code drives a decision. In practice there are usually five:

• Customer risk scoring and the business-activity factor in the risk assessment.
• Prohibited and restricted activity lists, often written as code ranges.
• Merchant categorisation for acquiring and pricing. Card merchant category codes are a separate scheme-defined list, but internal mappings between the two are common.
• Regulatory and statistical returns with a sector or activity breakdown.
• Credit data shared with lending partners or credit registers.

Each needs its own decision. For code-range rules the question is whether the range still means the same thing. For stored customer codes the question is whether the stored value is now a dead code.

6. The migration method: correspondence tables and the one-to-many cases

Every national institute publishes correspondence tables from the old classification to the new, and Eurostat publishes one between NACE Rev. 2 and Rev. 2.1. Most rows are one-to-one, so a mechanical conversion is safe. The risky rows are one-to-many: an old code whose activities now split across several successors. There, any automatic conversion, including the register’s own, had to choose one successor. The Belgian register says so openly.

A sound method has four steps. First, add a vintage field (“NACE Rev. 2”, “NACE Rev. 2.1”, national version and year) to every stored code, and never overwrite the old one. Second, run the correspondence table across the book and separate one-to-one from one-to-many rows. Third, resolve the one-to-many rows from the customer’s described activity, the register’s activity text or the customer’s own statements, not from the table. Fourth, rewrite code-range rules against the new structure, particularly anything that referenced sections J, K, L or M or the old retail channel codes.

After the switch, read a changed code on refresh against the correspondence table first. If the new code is the expected image of the old one, nothing happened. If there is no path between them, the customer’s activity may really have changed, and that belongs in a review.

7. Three scenarios from a live book

A Dutch webshop whose risk tier moved. Facts: a merchant onboarded in 2023 sat in a tier keyed to an SBI 2008 internet-retail code. A September 2025 refresh returns a five-digit SBI 2025 code for the goods it sells, which the firm’s rules do not recognise. Rule: NACE Rev. 2.1 removed the sales-channel distinction, and KVK recoded the register automatically. What the analyst does: confirms the new code through the published conversion scheme, records both vintages, and keeps the tier. The team then rewrites the e-commerce rule to use the firm’s own channel data instead of a code. Outcome: no false re-tiering, and a rule that no longer depends on a code that has gone.

A French merchant book before 2027. Facts: a firm prices French merchants from their APE code. Rule: NAF 2025 replaces the code for every SIRENE legal unit on 1 January 2027, and INSEE already publishes each business’s future code. What the team does: runs the correspondence table now. It pulls the future codes for the one-to-many cases and prices on the resolved code before the switch. Outcome: the January 2027 change happens without an unexplained shift in the portfolio’s risk profile.

A marketplace mistaken for a merchant. Facts: a platform applies for payment services and describes itself as a retailer. Its register code falls in a new intermediation class. Rule: intermediation classes cover firms that match buyers and sellers for a fee without owning the goods. What the analyst does: treats the code as a prompt to test the flow of funds. The question is whether the firm collects for third-party sellers, which changes the safeguarding and licensing analysis. Outcome: a structure question is raised at onboarding, not discovered in the first audit.

8. What to do, today

• Inventory every rule and field that uses an activity code, including card-code mappings.
• Add a vintage to stored codes and keep the old value.
• Rewrite section-based rules: finance is now L, IT is K, real estate is M.
• Resolve one-to-many conversions by hand, starting with the highest-risk activities.
• Diarise 1 January 2027 for France and before 2027 for Spanish state registers.
• Check national statistical returns for the classification version they now expect.

Related: Company registers compared across the EU · BCE/KBO — the Belgian enterprise number register · SIREN, SIRET and the RNE — French company registers