SE P A Step-by-step migration to SEPA Direct Debit - Spain

Financial Su
pply
Ch
ain
SEPA
Step-by-step migration to SEPA Direct Debit - Spain
1Collecting payments in the same way across Europe!
This publication describes the steps by which you need to go through to switch from the local “adeudo domiciliaciones” to the SEPA Direct Debit.
1. Where can you find information on SEPA Direct Debit?
ING puts at your disposal general information about SEPA as
well as detailed documentation related to SEPA Direct Debit,
including format, conditions and country specificities.
In addition, you can also find information on the following websites:
• ING SEPA website: www.ingsepa.com
• Official Spanish SEPA website: www.sepaesp.es
2. You sign a contract with ING for SEPA Direct Debit
Before you can start collecting via SEPA Direct Debit you must
sign a creditor contract with ING. Also, you will have to apply for
a creditor ID number. There are rules per country; in Spain, it is
build based on your NIF. As a creditor, you must use this ID with
every direct debit collection. This information will be displayed to
the debtor by its bank for each SEPA Direct Debit. You can use
the same creditor ID across all SEPA countries and no longer
need specific identification for each individual country.
Please contact your Payment & Cash Management consultant
for further details and the most up to date information.
ING will provide you with all required and detailed information
about applicable times required for processing, etc.
The SEPA Direct Debit consists of two versions, Core and business-to-business. The table below contains a short description
of the properties and differences between these two versions.
SEPA Direct Debit Core
SEPA Direct Debit Business-to-Business (B2B)
Creditors can collect from
Both consumers and non-consumers
Creditors can collect from
Only non-consumers
Pre-notification
14 days before receipt of direct debit, unless debtor and
creditor agree otherwise
Pre-notification
14 days before receipt of direct debit, unless debtor and
creditor agree otherwise
Type
For recurrent and one-off direct debits
Type
For recurrent and one-off direct debits
Deadlines for receiving payments*
One-off and first of recurrent direct debits:
The payment must be delivered to ING 6 days before
settlement / due date (D-6)
Recurrent:
The payment must be delivered to ING 3 days before
settlement / due date (D-3)
Deadlines for receiving payments*
All payments (one-off, first and recurrent) must be delivered to
ING 2 days before settlement / due date (D-2)
Right of refund
8 weeks after day of debiting
13 months if there is no valid mandate
Right of refund
13 months if there is no valid mandate
If you want to work with both types as creditor you will have to conclude two contracts with your bank.
* ING is currently working on improving these delivery times to:
SDD Core: D-5 for one-off and first direct debits and D-2 for recurrent direct debits
SDD B2B: D-1 for first, recurrent and one-off direct debits
Step-by-step migration to SEPA Direct Debit - Spain 2
3. SEPA Direct Debit mandates
The mandate is the expression of consent and authorisation
given by the debtor to allow initiation of collections for debiting
the specified debtor’s account.
The European Payment Council (EPC) has set several fields of
a mandate as mandatory in order to be considered as valid for
SEPA although the layout can be adapted freely.
If you do not wish to design new mandate documents yourself,
you can use our ING template (also available in Spanish)
on which you can print your data and logo. Please ask
your Payment & Cash Management consultant for a copy.
The SEPA mandate form must contain the following elements:
• Indication of Core or B2B mandate
• Legal text which is provided for Core or B2B mandates
• Creditor’s data: name, address, creditor ID
• Debtor’s data: name, address, IBAN, BIC
• Mandate reference. This reference must be unique and
consists of a maximum of 35 characters. In case of a
migration, this reference will replace the existing 12
characters one. Additionally and as the creditor ID, this
mandate reference must be provided to the debtors clients.
• Indication of whether the mandate is related to a one-off or
recurrent direct debit
• A description of the underlying contract (optional for Spain).
Step-by-step migration to SEPA Direct Debit - Spain 3
Note:
Unlike the SEPA Direct Debit Core, the SEPA Direct Debit B2B
must follow an additional process: the debtor must give confirmation to the debtor bank before the first collection occurs so
the mandate can be activated. For this purpose it must provide
the debtor bank with a copy of the B2B mandate, duly signed
by authorized people, stating names and positions. If the debtor
fails at this step, the collection cannot be executed. By doing
this, the debtor confirms the debit agreement according to the
SEPA Direct Debit B2B rules. This measure was added to provide the required guarantee for the B2B mandate, as there are
no rights to refund under SEPA Direct Debits B2B.
An illustration of the processes to authorise and receive payments for SEPA Direct Debit Core
Authorisation
process
1.Mandate
2.Signed mandate
Creditor
Collection
process
1.Application
to receive
payments
(incl. MRI*)
Creditor
Debtor
3.Digitalisation and filing
of mandate
Creditor’s
bank
3.Application
to receive
payments
(incl. MRI*)
2.MRI check
Debtor’s
bank
4.Debit
account
Debtor
An illustration of the processes to authorise and receive payments for SEPA Direct Debit Business-to-Business
(B2B)
Authorisation
process
1.Mandate
Debtor’s
bank
2a. Signed mandate
Creditor
Collection
process
1.Application
to receive
payments
(incl. MRI*)
Creditor
3.Digitalisation and filing
of mandate
Creditor’s
bank
* MRI = Mandate Related Information
Step-by-step migration to SEPA Direct Debit - Spain 4
3.Application
to receive
payments
(incl. MRI*)
2.MRI check
Debtor
2b. Mandate:
data, instructions and confirmation
Debtor’s
bank
5. Debiting
4.Check whether
MRI* is correct
Debtor
4. How can you switch from local “adeudo domiciliaciones”
to SEPA Direct Debit?
To limit the impact on all direct debit users, existing Spanish
mandates will be considered as valid for SEPA. Therefore, you,
as a creditor, will not have to request new mandates from your
debtor clients for the Core scheme.
To successfully migrate the existing mandates, the following
requirements defined by the AEB (Asociación Española De
Banca) have to be respected:
• Unique Mandate Reference: from the current 12 characters
to a maximum of 35 characters accepted reference. This
reference, linked to the creditor ID will become uniquely
recognizable throughout the SEPA area.
• Creditor ID (based on the Spanish “NIF”, Número de Identificación Fiscal) is mandatory and can be used across all
SEPA countries. It consists of:
- ISO county code (“ES” for Spain)
- Control key (2 characters)
- Business code (“ZZZ” by default)
- NIF identifier (9 characters).
• Sequence Type recurrent: The AEB considers all migrated
collections have to be sent as recurrent (“RCUR” value in
SequenceType <SeqTp> field).
• Date of signature: the date 31-10-2009 will be used in
Spain as the signing date for every migrated mandate,
regardless of the “real” date of signature. This will ease the
recognition of migrated mandates.
For the business-to-business scheme, a new mandate will have
to be signed by the debtor.
Note: the migration of existing mandates differs from country to country
If you already use other forms of direct debit in other European
countries, then consider that each country has different rules
for harmonising current mandates with the new SEPA Direct
Debit. We have compiled SEPA country fact sheets to help you
understand how this is regulated in other countries. For more
information, please visit www.ingsepa.com.
Step-by-step migration to SEPA Direct Debit - Spain 5
5. A new product, a new format?
The SEPA direct debit format is based on UNIFI (ISO 20022)
XML message standards (pain.008.001). The European Payments Council has also strictly limited the character set that can
be used in the messaging.
Ask your software supplier about the system readiness and
required adjustments needs to support this new format. You
must also check what the impact may be on your reporting and
reconciliation processes.
In Spain, AEB local formats have been made SEPA-compliant.
ING supports those formats too (AEB19.14 for Core and
AEB19.44 for B2B).
Note: ING offer extensive possibilities to test your XML formats
and help you in case format adaptations are not achieved in a
timely manner via an external partner.
6. Which channels support SEPA Direct Debit?
The following digital banking channels support SEPA Direct
Debit: Telelink@Isabel, SwiftNet and FTP.
7. Using SEPA Direct Debit implies new deadlines
When sending SEPA Direct Debit collections to ING, please
bear in mind the following timeframe:
SEPA Direct Debit Core
D-14
D-6* D-5
D-3* D-2
D
D+8
weeks
D+13
months
D-14
D-6*
D-5
D-3*
D-2
D
Deadline on which pre-notification must be sent
A one-off or a first of a recurrent collection should be delivered by you to ING ultimately 6 working days before
desired due date / execution date (delivery may be made as of 6 months before due date or the date on which
first payment is received, at the earliest)
Deadline for ING to deliver a one-off or first of a recurrent payment to the debtor’s bank
A recurrent collection should be delivered by you to ING ultimately 3 working days before desired due date /
execution date (delivery may be made as of 6 months before due date or the date on which first payment is
received, at the earliest)
Deadline for ING to deliver a recurrent payment to the debtor’s bank
D = Due date = Desired execution date = Value date = Settlement date
On the execution date the direct debit amount will be credited on the creditors account.
D+8 weeks D+13 months End of refund period
End of refund period in the case of an invalid mandate
*
ING is currently working on improving these delivery times to:
D-5 for one-off and first direct debits and D-2 for recurrent direct debits
SEPA Direct Debit Business-to-Business (B2B)
D-14
D-2*
D-1
D
D+13 months
D-14 D-2*
D-1
D
Deadline on which pre-notification must be sent
All collections should be delivered by you to ING ultimately 2 working days before desired due date / execution
date (delivery may be made as of 6 months before due date or the date on which first payment is received, at
the earliest)
Deadline for ING to deliver the payment to the debtor’s bank
D = Due date = Desired execution date = Value date = Settlement date
On the execution date the direct debit amount will be credited on the creditors account.
D+13 months End of refund period in the case of an invalid mandate
*
ING is currently working on improving these delivery times to:
D-1 for first, recurrent and one-off direct debits
Step-by-step migration to SEPA Direct Debit - Spain 6
8. As a creditor, you are obliged to send pre-notification to
your debtor clients
According to SEPA Direct Debit rules, you must inform your
debtor client in advance of the debited amount that to debit
and when it will take place. In principle, you must send the
pre-notification at least 14 calendar days before the payment
date, unless it has agreed otherwise with the debtor. A similar
agreement can be included in its general terms and conditions
of sale, for instance.
9. Inform your debtor clients that you are using SEPA Direct
Debit
As a creditor, you have the obligation to inform your debtor
about the method you use to make collection. As a consequence, you will have to let the debtor know about SEPA Direct Debit
and SEPA properties before starting to do collections.
Furthermore, it is sufficient to send one pre-notification annually
if you will debit the same amount at the same intervals. You can
also send the pre-notification together with the invoice or include
it in the invoice.
10. Congratulations! You are now ready to use the SEPA Direct Debit
Step-by-step migration to SEPA Direct Debit - Spain 7
More information
The registered office of ING Bank N.V. is located at
Bijlmerplein 888, 1102 MG Amsterdam, Trade Register number
33031431 in Amsterdam. ING Bank N.V. is registered with the
Dutch Central Bank (DNB) and the Netherlands Authority for the
Financial Markets (AFM) in the Credit Institutions and Financial
Institutions Register. ING Bank N.V. is also subject to the supervision of the Netherlands Competition Authority (NMa). Information about the supervision of ING Bank N.V. can be obtained
from the DNB (www.dnb.nl),
the AFM (www.afm.nl) or the NMa (www.nmanet.nl).
In the context of this publication ‘ING’ and ‘bank’ are understood
to mean: ‘ING Bank N.V. ’
PCM191 1013 © ING Belgium SA/NV
For more information on
SEPA please contact your
Payments & Cash Management
consultant or visit
www.ingsepa.com, or
www.sepaesp.es