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
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