On 2 September 2019, the European Payments Council (EPC) published recommendations for all participants in Single Euro Payments Area (SEPA) schemes in the event of a no-deal Brexit on 31 October 2019. The guidance follows an earlier EPC decision in March 2019 that approved an application from UK Finance for the continued participation of UK payment service providers (PSPs) in SEPA schemes in the event of a no-deal Brexit (see previous blog post here).

From a payments perspective, in the event of a no-deal Brexit, as of 1 November 2019 the UK will be considered as a non-European Economic Area (EEA) SEPA country such as Andorra, Guernsey, Isle of Man, Jersey, Monaco, San Marino, Switzerland and Vatican City State.

The EPC strongly encourages all SEPA payment scheme participants to implement the following recommendations without delay:

  • SEPA transactions to be executed or settled as of 1 November involving a UK-based SEPA scheme participants must contain the full address details of the originator or debtor and the bank identification code (BIC) of the beneficiary bank or debtor bank if explicitly requested; and
  • identify as soon as possible customers with incoming and outgoing cross-border SEPA transactions involving both a UK and an EEA payment account and to inform all customers concerned about the need to provide extra SEPA transaction data.