Instant Payments Regulation: Implementing Reporting Requirements Efficiently – Excel Upload or an Integrated Reporting Solution?

With the Instant Payments Regulation (EU) 2024/886, the European Union has established mandatory rules for the use of real-time transfers (instant payments) within the SEPA area. While many payment service providers already implemented the operational aspects—such as 24/7 processing, payee verification, or adjustments to sanctions screening—last year, another aspect has come into the focus of supervision since April 9, 2026: regulatory reporting.

The Instant Payments Regulation supplements the existing SEPA Regulation with new, uniform reporting requirements. Going forward, payment service providers must submit their data in a structured format to the relevant national supervisory authority. In Germany, submissions are made via BaFin and the MVP portal. The first report was due by April 9, 2026 at the latest and covers a retroactive period starting October 26, 2022¹.

New Reporting Requirements Under the Instant Payments Regulation

The legal basis for the reporting requirement is Article 15(3) of the SEPA Regulation, as amended by Regulation (EU) 2024/886. Accordingly, payment service providers are required to submit annual information on:

• the number and volume of credit transfers and real-time transfers,
• the fees for credit transfers and real-time transfers,
• the fees for payment accounts,
• as well as the number of rejected payment executions that were denied due to targeted financial restrictive measures.

The data on the number and volume of (real-time) transfers must be reported separately according to the recipient’s location (domestic, cross-border), the fees charged (free of charge, subject to fees), and the customer type (retail customer, corporate customer).

Figure 1 shows an excerpt from the corresponding BaFin reporting sheet for outgoing transactions. Similar breakdowns must be provided when reporting information on fees, while rejected payment executions are distinguished according to the institution responsible (PSP of the payer, PSP of the payee).

Data is collected on a calendar-year basis; reporting formats are standardized and subject to strict plausibility and validation rules¹. The aim of the regulation is to ensure transparency regarding the pricing, usage, and impact of instant payments in the European payments system. National supervisory authorities forward the aggregated information to the European Commission and the European Banking Authority (EBA)².

Two Ways to Submit a BaFin Report

For the technical implementation of reporting requirements, BaFin provides for two permissible submission methods:

1. Uploading a completed Excel template via the MVP portal
2. Automated reporting via reporting software, for example within existing reporting systems

According to the Instant Payments Regulation, both methods are equally permitted under regulatory standards—but differ significantly in terms of operational effort, scalability, and integration into existing processes.

Excel upload: Regulatorily permissible, operationally demanding

The Excel-based reporting method uses a template provided by BaFin, which must not be structurally altered and is subject to predefined validation and plausibility checks during upload. The file must be uploaded via the MVP portal and forms the formal basis of the report¹.

From a project perspective, it is evident that this approach may be particularly suitable for institutions with low complexity or as a short-term entry-level solution. At the same time, it involves a significant amount of manual effort that should not be underestimated. The required information must be consolidated from various source systems, correctly aggregated, and consistently maintained across multiple reporting years. Changes to fee models, product structures, or sanctioning logic directly impact the reporting logic and increase the need for coordination between business units, IT, and reporting.

In addition, technical inquiries or validation errors often require in-depth regulatory knowledge. While the Excel template provides formal checks, it does not replace subject-matter expertise or audit-proof traceability over extended periods.

BaFin makes the currently valid and up-to-date version of the upload file available on the MVP portal³. This means it must be reviewed annually for potential changes, and the reporting and calculation logic must be adjusted accordingly as needed.

Automated Reporting as Part of the Reporting Architecture

Against this backdrop, many institutions are relying on an integrated solution for regulatory reporting. Reporting software, such as BAIS, enables the requirements of the Instant Payments Regulation to be embedded directly into existing reporting processes⁴. The calculation of reporting metrics is rule-based and drawn from the central data repository, including validations, historical tracking, and transparency down to the individual transaction level.

The approach presented on Banking.Vision demonstrates how Instant Payment Reporting can be seamlessly integrated into an established reporting environment⁵. This ensures that reporting is not treated as an isolated obligation, but rather as an integral part of a consistent overall regulatory architecture.

Such an approach becomes particularly important when reporting is designed to be annual, audit-proof, and expandable in the future—for example, with regard to additional EBA standards or future requirements from PSR and PSD3.

Which solution is right for which institution?

In practice, there is no one-size-fits-all recommendation. Rather, the choice of reporting channel depends on several factors:

• The Excel upload can be useful if
  • the volume of reports is manageable,
  • the immediate priority is to formally comply with the obligation,
  • or a central reporting infrastructure does not yet exist.
• An integrated reporting solution is recommended if
  • reporting processes are to be designed to be sustainable, repeatable, and audit-proof,
  • other regulatory reports are already being generated automatically,
  • or further regulatory expansions are expected in the medium term.

Conclusion: Reporting is more than just a formality

With the Instant Payments Regulation, a new phase of regulatory transparency is beginning for many payment service providers. Reporting requirements are not a one-time project, but rather part of an ongoing regulatory dialogue between institutions and regulators.

With experience in both Excel-based reporting procedures and the integration of automated reporting solutions, msg supports institutions as a consulting partner in selecting and implementing a suitable reporting approach. The decisive factor here is not the tool alone, but a clearly defined target vision that harmonizes regulatory requirements, data availability, and operational processes.