The first harmonised reporting deadline under the SEPA Instant Payments Regulation falls on April 9, 2026, requiring every payment service provider in the EU to submit standardised data covering more than three years of historical operations to their national competent authority.

This is not a routine quarterly filing. The first report is a cumulative retrospective spanning October 26, 2022 through December 31, 2025 - approximately 3.25 years of transaction and pricing data that PSPs must reconstruct and submit in a standardised format that many had never previously used.

Why April 2026 and Not April 2025

The original deadline was set for April 2025 under Article 15(3) of Regulation (EU) 2024/886, which amended the SEPA Regulation. The European Banking Authority recognised that PSPs were not ready and published Implementing Technical Standards (EBA/ITS/2025/02) postponing the deadline by twelve months. The Commission operationalised this delay through Implementing Regulation (EU) 2025/1979.

The EBA has advised national competent authorities to deprioritise enforcement actions related to the original timeline, effectively granting a soft amnesty for the transition period.

What PSPs Must Report

The reporting obligation covers two categories of data across six standardised templates (S 01.01 through S 04.00):

Charges and pricing data. PSPs must report the fees they charge for credit transfers, instant credit transfers, and payment accounts. This is designed to give regulators visibility into whether PSPs are complying with the regulation's requirement that instant credit transfer charges must not exceed those for standard credit transfers.

Rejection rates from sanctions screening. PSPs must report rejection rates resulting from Transaction Filtering and Recipient Matching (TFRM) processes - the sanctions and terrorist financing screening that the regulation requires for instant payments. High rejection rates could indicate overly accelerated screening that effectively undermines the instant payment mandate.

The Compliance Burden

The retrospective nature of this first report creates a significant data reconstruction challenge. PSPs must assemble 3.25 years of historical data into templates that were only finalised in 2025. Many institutions did not collect data in the granularity or format the templates require, meaning they must retroactively map legacy data to the new reporting structure.

Industry surveys suggest that preparation levels vary significantly. SBS Software reported that only 33% of PSPs considered themselves fully prepared as of early 2026.

What Happens After Submission

National competent authorities will aggregate the PSP-level data and forward it to both the EBA and the European Commission by October 2026. The Commission will use this data to assess whether the pricing and access objectives of the Instant Payments Regulation are being met across the single market.

Subsequent reports will be annual, covering single calendar years, making the data collection burden considerably lighter after this initial retrospective filing.

Implications

For PSPs that have not yet begun preparation, the April 9 deadline leaves less than four weeks. The six reporting templates require granular data on transaction volumes, pricing structures, and sanctions screening outcomes that may span multiple internal systems.

The reporting framework also establishes an ongoing supervisory tool. Once the baseline data is collected, regulators will have standardised metrics to monitor whether instant payments are genuinely becoming the default across the eurozone - and whether any PSPs are using pricing or screening practices to discourage adoption.