The EBF supports the objective of strengthening payment transparency and ensuring that relevant information about the parties to a payment can remain available throughout the payment chain. Payment transparency helps ensure that information about the originator and beneficiary of a payment is available to relevant financial institutions and authorities, supporting efforts to prevent and detect financial crime and fraud. At the same time, the EBF emphasises the need for the Guidance to remain risk-based, proportionate and aligned with the different roles and responsibilities of participants in the payment chain.

The EBF also calls for clear and practical guidance on the responsibilities of financial institutions involved in processing payments. Institutions should be able to rely on information available to them within their role in the payment chain, without being subject to requirements that go beyond what they can reasonably obtain or control. The implementation of Recommendation 16 should also not create additional customer identification, verification or due diligence obligations beyond those already applicable.

Finally, the EBF stresses the importance of ensuring that the Guidance is practical and workable across different payment models and infrastructures. A clear, proportionate and sufficiently flexible approach will be essential to support consistent implementation of the strengthened Recommendation 16 without creating unnecessary operational burdens.