Corporate treasurers are reporting that they are finding some banks are not ready to accept SEPA payments, while other banks are coming back with vague error messages. The large MNCs are mostly ready, but many SMEs are not ready. This is not a problem until the legacy ACH systems close, then it could be major. It is important to remember that the legacy ACH systems are not all closing on 1 August 2014. Some are already closed, while in other countries there are many different closing dates, viz:

• countries already closed: Slovakia - migrated on mass on February 1st; Finland - already use SCT and have just implemented SDD 
• countries that will not use full six month extension: Belgium - limit to two months; Ireland - limit transition to March 31st; Spain - processing of legacy ACH transactions will not be possible post 17th March and post 9th June for legacy direct debit transactions
• countries who have announced other limitations: Germany - legacy B2B Direct Debit scheme not permitted post 1 February, others permitted; Italy - all legacy ACH transactions must be SCT compliant by 1 February, now legacy DD mandates allowed after February 28th, and corporates not allowed mixture of legacy DD and SDD; Luxembourg - no legacy DD mandates or DD payments post 1 February
• other countries - France, Austria, Portugal, Netherlands: processing of legacy transactions will be permitted post 1 February. However, all markets have strongly reiterated the need for organisations to complete migrations to SEPA.

Various minor (maybe major?) SEPA issues remain including: 

• great variation in SEPA Direct Debit fees between the banks, e.g. Greek charging a fee of EUR 19/SDD 
• BICs at some banks seem to have changed
• some Banks have a BLZ code but without BIC
• some banks still will not permit their customers to submit PAIN.001 formatted payments
• etc.

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CTMfile take: The real test will be when the legacy systems close. We have had no reports on the position in Slovakia and Finland where they have already closed.