What is IPR reporting? Instant Payments
The Instant Payments Regulation introduced 24/7 instant euro transfers — and a brand new annual statistical return that every PSP in the euro area now has to file. The first deadline is 9 April 2026, the data covers four calendar years back to 2022, and the format is the EBA PAY-4.2 taxonomy. This piece walks through what is reported, where it goes, what to do if your historic data does not match the new schema, and how the national supervisors are diverging on the details.
1. What the IPR reporting obligation is
The Instant Payments Regulation — Regulation (EU) 2024/886, amending Regulation (EU) 260/2012 — requires every euro-area PSP to offer 24/7 SEPA Instant Credit Transfers, with funds available to the payee within ten seconds, and with charges no higher than for a standard credit transfer. To monitor compliance, the IPR introduced a new annual statistical reporting obligation, fleshed out by Implementing Regulation (EU) 2025/1979 and the EBA’s PAY-4.2 reporting taxonomy.
Reporting is done annually, to the PSP’s home-state competent authority (BdE in Spain, DNB in the Netherlands, BaFin in Germany, ACPR in France, Banca d’Italia in Italy, CSSF in Luxembourg, and so on). The first reference date is 9 April 2026 — and that first submission must cover the four calendar years from 2022 to 2025.
2. Who must report
Every payment service provider authorised in the euro area that handles SEPA credit transfers — credit institutions, payment institutions, electronic-money institutions, and post office giro institutions. There is no de-minimis threshold: a PSP that processes a single SEPA credit transfer in the reference year is in scope.
3. What data is reported — the six PAY-4.2 forms
The PAY-4.2 taxonomy is six tables. They are filed together as one annual submission:
| Form | Code | What it captures |
|---|---|---|
| S_01.01 | [7811] | Total number and value of credit transfers and instant credit transfers — in national currency |
| S_01.02 | [7812] | Total number and value of transfers — in euros (summary view) |
| S_02.01 | [7813] | Charges levied for credit transfers and instant credit transfers — in national currency |
| S_02.02 | [7814] | Charges in euros (summary view) |
| S_03.00 | [7815] | Total number of payment accounts and total charges per account — in national currency |
| S_04.00 | [7816] | Number of denied instant credit transfers — including refusals linked to sanctions screening |
Each form has multiple breakdowns — by initiation channel (online banking, mobile, paper), by location of the counterparty PSP (national vs. cross-border), by whether charges were applied, and by user type (consumer vs. non-consumer).
4. Why the charges tables matter
S_02.01 and S_02.02 are the supervisor’s lens on the IPR’s fee-parity rule: charges for an instant credit transfer must not exceed those for an equivalent standard credit transfer. By collecting the two figures side by side at a national level, supervisors can see at a glance whether a PSP is charging instant differently from standard. Outliers will be asked questions.
5. The first deadline — 9 April 2026
National supervisors have already opened their reporting channels:
- Banco de España publishes the PAY-4.2 templates and reconciliation guidance on its supervisory-reporting portal under Implementing Regulation (EU) 2025/1979.
- DNB made the IPR reporting obligation available in the Digital Loket Rapportages reporting service in March 2026.
- BaFin / Bundesbank have routed the IPR returns through the BAIS modules VD260 and VD260a, accepting XML or XBRL.
6. The “back to 2022” problem
The single biggest practical issue with the first submission is that PAY-4.2 did not exist when the data was generated. Most PSPs do not have 2022–2024 data sitting in PAY-4.2 shape — they have it in other internal cuts, legacy regulatory cuts, or in payment-system data warehouses that pre-date the new taxonomy.
Three things to know about that:
- National-format variation for legacy years. Some supervisors (notably BdE and BaFin) accept pre-2025 data in simplified or alternative formats, with reconciliation rules that differ from the strict PAY-4.2 schema applied to 2025 onwards. Always check the local guidance before mapping legacy years.
- Do not invent precision. Where 2022 data does not break down by, say, “initiation channel” because your system did not record it, the right answer is to leave that breakdown unfilled rather than estimate. Supervisors are explicit on this.
- Reconcile with what you already filed. Many PSPs already submitted historic SEPA volumes to national supervisors under earlier regimes. Your IPR submission for 2022–2024 should reconcile to those returns at the totals level. A mismatch is the single most common audit trigger.
7. National variations to watch
The PAY-4.2 schema is a single EBA taxonomy, but the national reporting layers around it diverge:
- Spain — BdE adds national correspondence tables and accepts data in EUR or in the entity’s reporting currency; both S_01.01/S_02.01 (national currency) and S_01.02/S_02.02 (EUR) must be filed when these differ.
- Netherlands — DNB ingests via DLR with XBRL only; the channel went live on 4 March 2026.
- Germany — Bundesbank/BaFin route through BAIS VD260/VD260a; both XML and XBRL accepted.
- France / Italy / Luxembourg — ACPR / Banca d’Italia / CSSF use their existing supervisory portals; all three have published mapping notes against the EBA schema.
8. Build, buy, or hybrid
The XML/XBRL generation itself is not the hard part — it is the data-warehouse work to align historic transactional records to the PAY-4.2 breakdowns. Three real options:
- Build in-house. Sensible if your data warehouse already tags credit transfers by initiation channel, counterparty location, and user-type. The supervisor-side submission is then just a thin XBRL/XML export.
- Buy a managed service. Specialist regulatory-reporting vendors (most of the FINREP/COREP houses now cover PAY-4.2) handle the schema and the country-by-country submission for an annual fee.
- Hybrid. Build the data layer once internally (it is reusable for AnaCredit, BSI/MIR and other statistical reporting), and outsource only the country-specific submission gateway.
9. FAQ
What is the first deadline for IPR reporting?
9 April 2026. The first submission covers the four preceding calendar years (2022, 2023, 2024 and 2025). After this first wave, reporting is annual on the same April reference date.
I have data going back to 2022 — but not in the PAY-4.2 format. What now?
Most PSPs are in the same boat. National supervisors typically accept pre-2025 data in simplified or alternative national formats, with reconciliation guidance published locally (BdE and BaFin both have explicit notes). Where a breakdown did not exist in your historic data — for example, “initiation channel” in 2022 — leave it unfilled rather than estimate.
Does the IPR reporting cover SEPA Direct Debits?
No. PAY-4.2 is scoped to credit transfers (regular and instant). Direct debits and card payments sit in other reporting frameworks.
Where do I file?
To your home-state competent authority — BdE in Spain, DNB in the Netherlands, BaFin in Germany, ACPR in France, Banca d’Italia in Italy, CSSF in Luxembourg. Each has its own portal and its own taxonomy version (XML or XBRL). PSPs operating across borders on a Freedom-of-Services passport file only with their home supervisor for IPR reporting — unlike CESOP, this is a home-state-only return.
Is there a de-minimis threshold?
No. Any PSP that processes SEPA credit transfers is in scope. There is no minimum volume below which the obligation falls away.
What if my fees for instant transfers are higher than for standard ones?
That is a breach of the IPR fee-parity rule. The S_02.01 / S_02.02 charges tables make any divergence visible to your supervisor at the first submission. Fix the price-list before April 2026, not after.
What about denied transfers — what counts as “denied”?
S_04.00 captures every refused instant credit transfer, including those refused for sanctions-screening reasons. The level-of-detail breakdown distinguishes refusal reasons (insufficient funds, sanctions match, technical, payee unreachable, etc.).
10. What to do, today
If your IPR project has not yet kicked off, the priority order is:
- Map your data. Take the PAY-4.2 schema and walk the six forms field by field against your payments warehouse. Identify which breakdowns you can populate cleanly and which need legacy fallbacks.
- Read your national guidance. The EBA schema is one thing; your supervisor’s national note is another. BdE, DNB and BaFin all publish local interpretation. Read it before you build.
- Check fee parity. If your instant-transfer fee is higher than your standard-transfer fee, fix it before the first submission, not after.
- Plan a dry run for Q4 2025. A test submission against your supervisor’s sandbox catches reconciliation breaks before the live deadline.
Looking ahead: many of these obligations will be re-codified in the PSD3 / PSR package.
Related: What is CESOP reporting? · How to launch Dutch IBANs · What is the Banking Information Reference Portal?
