It has now been just over three months since banks activated VoP usage. Fortunately, the big storm, figuratively speaking, did not materialize. German banks did not activate the relevant functionalities all at once, but rather at different times. This led to a sharp increase in the workload for our hotline, but fortunately this was spread out over the week from October 6 to 10.
However, it also became apparent that additional adjustments still had to be made for customers at the beginning of November, as banks acted and continue to act in a heterogeneous manner. We know of two banks in Germany that strictly adhere to the legal requirements. At these banks, SEPA collective payments are only processed via the opt-in process. All other credit institutions connected to ATAQ customers also allow the opt-out procedure for these special cases.
The use of the VoP check is currently very selective among corporations. The functionality is not in widespread use. There is only one customer in the ATAQ family who goes through the opt-in process 100%. In the first two weeks, it was found that there was a 50-50 distribution in the responses from the recipient banks, with 50% showing no reaction and the other 50% containing the three other status messages.
Fortunately, this behavior has changed since the beginning of November. Non-responses/protocols are now rare. It should be noted that opt-in requests for SEPA payments to France and Spain have also yielded results for customers. In our view, there is still room for improvement in the current data reconciliation process, and quality depends heavily on the bank. We believe that this area should be refined. However, we see a manageable positive recognition rate and expect better results in the future.
The bank statements provided are inconsistent throughout the entire process. These may be marginal deviations between banks, but they are significant in terms of machine analysis and the associated evaluation. We recognize here a different interpretation of the technical specifications. This leads to a high level of effort on our part to interpret the different variants correctly. This process is still in progress and is being continuously optimized. Adjustments are currently being designed and must be adapted or refined based on the data provided.
In addition to the technical side, we also noticed changes on the technical side: the response time behavior of the bank computers. At the end of September and beginning of October, we noticed that some EBICS hosts were temporarily unavailable. We assume that program changes for VoP were implemented during this time. This behavior is no longer observable. It should be noted that VoP generates significantly more load. This was highlighted in discussions with the banks and also confirmed by them. We are monitoring this development. The banks have made administrative changes on the host side for the use of the VoP process. Here, too, it should be noted that not everything has worked 100 percent. With one exception, the banks were cooperative and very solution-oriented when it came to making the necessary adjustments.
Conclusion:
The introduction was a bit bumpy. The decision not to enforce the legal requirements completely led to the implementation not ending in chaos, but rather to no significant damage despite some friction losses. Solutions were found for all problems. The technical platforms used by banks must continue to be monitored. It must be made clear once again that if all customers were to switch to 100% opt-in, the current infrastructure would be completely overwhelmed.