In January 2013 the EPC published the results of their survey of the specific migration rules that need to be taken into consideration when initiating cross-border SDD collections. This survey was supposed to have restricted circulation, but the results are starting to emerge as corporates get grips with exactly how they should set up cross-border SEPA Direct Debits. Not surprisingly, given the different development paths of the local ACHs, another layer of complexity and extra rules has been revealed, e.g. in the Netherlands to transition a legacy direct debit mandate to a SEPA core direct debit mandate requires a mandate date of November 2009, while transitioning a legacy DD mandate in Belgium the legacy number needs to be preceded with DOM80 and put the transaction indicator flag to 'True', in Spain the DD system never has a first payment - it will always be recurring despite it being a SEPA instrument.

This is a real nightmare for cross-border SDDs, e.g. if a company sends an SDD to the ACH in Netherlands for collection of a payment in Spain which rules apply: the Dutch or the Spannish?

These new rules will have large ramifications for corporates trying to implement SEPA wide direct debit programmes, particularly on the level of customisation required in each country's ERP direct debit database and processes.

Going local and the postponement of the pan-European ACH dream
To avoid these complications and anomalies and to ensure that they will be able to continue their collections, some large SDD users are making everything local: setting up local collections, local accounts, local CSIDs, etc. This, at the very least, postpones the birth of the true pan-European ACH because until the rules for SDDs are consistent and understandable SEPA wide, the large companies, who make up the bulk of the payment traffic, will only do local SDD, they just won't use cross-border regardless how much the Central Banks threaten.

---

This will take years, if ever, to be sorted out.