The hardest part of the EU’s instant payments deadline for e-money and payment institutions is not sending money in ten seconds. Scheme access, settlement and the payment rails themselves are now well understood. The harder part is everything an EMI’s own platform has to do around each payment, in the same ten seconds, every day of the year.
Under the Instant Payments Regulation, electronic money institutions (EMIs) and payment institutions (PIs) in the euro area must be able to receive and send instant euro credit transfers by 9 April 2027. Those outside the euro area must receive by the same date and send by 9 July 2027, according to the European Central Bank (ECB, 2026). That leaves less than six months for firms that have not started.
Many EMIs are planning for this as a connectivity project: pick a sponsor bank or direct participation route, connect to the scheme, test, go live. That plan misses the parts of the regulation that land on the ledger, the customer channels and the compliance stack.
Those parts live in what most firms would call their digital banking core: the platform that holds customer accounts and balances, runs onboarding, issues cards and pushes every transaction to the app. Velmie, which designs, implements and operates digital banking and payments programs for regulated institutions, describes a modular platform covering IBAN accounts, onboarding, cards, lending, savings, P2P and international payments, with white-label apps on top. The test for any such platform is blunt: can it keep up with instant?
What does the regulation actually require of EMIs?
The regulation requires EMIs and PIs that offer euro credit transfers to offer instant ones too, at no higher price, around the clock, with sanctions checks that do not slow the payment. Funds must reach the payee’s account within ten seconds of the payer’s provider receiving the order, under Article 5a of Regulation (EU) 2024/886.
Four obligations matter most for platform teams:
- Reach: receive instant transfers, then send them, by the dates above.
- Price parity: charges for instant transfers may not be higher than charges for other credit transfers of the same type (Article 5b).
- Sanctions screening: firms must check at least daily whether any of their payment service users are subject to EU targeted financial restrictive measures (Article 5d), instead of screening each instant transfer in flight.
- Payee checks: Verification of Payee has applied to every euro area payment service provider, EMIs and PIs included, since 9 October 2025 (Article 5c), so the payee check has to run inside the same instant flow.
Why is this a core platform problem?
An instant payment is only as fast as the slowest system it touches. If the ledger posts in batches, if balance checks call a legacy service, or if fraud scoring runs on a queue, the scheme connection will be ready and the payment still will not be.
“Most EMIs we speak to have the scheme connection on a project plan. Far fewer have checked whether their ledger, card authorization and fraud rules can all answer inside ten seconds at three in the morning on a Sunday,” said Slava Ivashkin, CEO of Velmie. “That is where instant payments projects slip.”
EMI platforms are most often caught out in three places:
- Real-time ledger and balances. Customers will expect incoming instant funds to be spendable at once, including on their card. A ledger that reconciles overnight cannot support that.
- Round-the-clock operations. Instant payments run 24 hours a day, 365 days a year. Release windows, maintenance jobs and support rosters built around business hours need rethinking.
- Fraud controls without delay. With no time for manual review, fraud and authorized push payment scam checks must run inside the ten-second window, and their thresholds must be tuned for speed.
Does direct access to TIPS change the picture?
Direct access helps, but it adds work as well as removing a dependency. Since October 2025, non-bank PSPs that meet the requirements of the TARGET Guideline can access TARGET Services, including TIPS, the Eurosystem’s instant settlement service (ECB, 2026).
For larger EMIs, direct participation cuts reliance on sponsor banks and their cut-off times. It also brings liquidity management, settlement account monitoring and direct operational accountability onto the EMI’s own platform. Smaller firms may still be better served by an agency model while they fix the core issues above.
What should EMIs check before 9 April 2027?
A short readiness checklist covers most of the risk. Each item should have a named owner and a test date.
- Ledger posts instant credits and debits in real time, with balances available to the card authorization system at once.
- Pricing engine applies the same fee to instant and regular euro credit transfers of the same type.
- Daily sanctions screening of the full customer base runs automatically, with a documented process for hits.
- Verification of Payee requests and responses run inside the instant payment flow, with clear messages in the app.
- Fraud and scam rules run inside the ten-second window and have been load-tested at peak volumes.
- Monitoring, alerting and on-call support cover nights, weekends and public holidays.
- Customer app shows instant transfer status, limits and failures in plain language.
What EMIs should do now
The April 2027 deadline will reward EMIs that treat instant payments as a test of their whole platform, not of one connection. Scheme access is the visible milestone, but ledger speed, round-the-clock operations and in-flow compliance decide whether payments actually arrive in ten seconds.
Firms with less than six months left should run the checklist this quarter, fix the slowest system first and leave the scheme connection to last. It is the part they can buy most easily.
