Eba Clearing Annual Report 2018 Double Page View
Eba Clearing Annual Report 2018 Double Page View
Eba Clearing Annual Report 2018 Double Page View
Practitioners Creating
Pan-European
Payment Infrastructures
Cover: View of La Défense in Paris from Arc de Triomphe
Main River walkway with Frankfurt skyline in the back
ANNUAL REPORT
2018
Infrastructure systems like plumbing, electrical wiring, gas pipe- Practitioners Creating Pan-European
lines or the metro are often invisible to those using them. But all Payment Infrastructures
visible architecture relies on this invisible fabric to serve the people
it has been built for. It is the underlying infrastructure that turns
our buildings and cities into places where we can live and work.
This report gives visibility to some of the people behind our infra-
structure. Our thanks go to the members of the Board, the
EURO1 Business Committee and the Operations and Technical
Group – for contributing to this report, but most importantly for
ensuring our infrastructure is user-driven and fit for purpose.
Panorama view of the city as seen from the roof of the Milan Cathedral
60 Corporate Governance
16 THE COMPANY’S ACTIVITIES 76 Oversight of the Payment Systems 90 APPENDICES 100 Appendix 4:
IN 2018 AND of EBA CLEARING List of Direct Participants
OUTLOOK FOR 2019 92 Appendix 1: in STEP2 CC
81 EBA CLEARING’s List of EBA CLEARING
18 Our Services Subsidiary PRETA Shareholders 100 Appendix 5:
18 Introduction List of Direct Participants
Annual Report 2018
EBA CLEARING
44 Operations in STEP2-T
4 104 Index
5 104 Index
The Company’s
Mission and
Strategic Aims
Our mission
EBA CLEARING aims to allow cost optimisation for its users, and is not
E xcellence
seeking profit or shareholder value maximisation. In pursuing its mission,
U ser-driven
EBA CLEARING is guided by the objective to offer its users solutions that
R obustness
are fit for purpose and efficient, with a special focus on safety and ensuring
O penness to stakeholders’ needs
compliance with regulatory and oversight requirements. EBA CLEARING
P an-European
recognises its role in supporting financial stability and promoting fair and
A gility
efficient markets; it is committed to discharging these responsibilities.
EBA CLEARING Annual Report 2018
In trade and supply chain finance, for example, recent industry initiatives
have led to the set-up of fully digitalised platforms or networks to support
international trade. And in the capital market space, different players have
been pioneering solutions enabling end-to-end digital issuance of debt
financing instruments, thereby broadening the access to capital for institu-
tional but also private investors.
Banks and other market players embracing
digital transformation are facing a twofold These market trends are further boosted by regulatory changes, such as
the new AML5 Directive. In force since July 2018, it recognises electronic
challenge: the need for fit-for-purpose digital identification based on the eIDAS Regulation as a valid way to identify cus-
payment instruments as well as the need for tomers, which contributes to the digitalisation of KYC and other processes
in the financial sector.
instant and intraday liquidity.
In the European payments space, the take-off of mobile payment solutions
driven by global players has demonstrated that merchants are eager to on-
As a provider of pan-European payment board ‘digital native’ payment instruments with a potential for wide accept-
infrastructure systems, EBA CLEARING ance. Consumers and corporates alike are embracing digitalisation as the
new normal and are expecting convenient, tailor-made and safe solutions
supplies the backbone supporting its large from all their service providers, including their banks.
user community in meeting both these
As European banks and other market players are embracing this digital
needs in a very reliable manner. transformation and developing new business models for the emerging eco-
EBA CLEARING Annual Report 2018
system shaped by PSD2 and Open Banking, they are facing a twofold chal-
lenge: the need for fit-for-purpose digital payment instruments as well as the
8 104 Chairman’s Statement
need for instant and intraday liquidity. And more often than not, these needs
have to be addressed not only for one national market but across Europe.
With the timely launch of RT1 in 2017, EBA CLEARING put at the disposal As part of its responsibilities as a SIPS operator, EBA CLEARING has in the
of the European payments industry a highly agile real-time infrastructure period under report continued to attach prime importance to the resilience of
platform. RT1 has been very successful at building up pan-European reach, its systems and their underlying IT architecture, has stayed on top of its risk
thanks to its different access and participation options. An additional suc- environments, and maintained a continuous dialogue with the Overseers of
cess factor is that the Company keeps evolving the system to satisfy the its systems in the context of assessments of compliance with oversight
needs of its growing user community – RT1 has just gone through its fourth requirements.
iteration and there is more to come.
Since the constant evolvement of state-of-the-art security and cyber secu-
Another major focus over the past year was put on making the established rity standards in line with best industry practices is of particular importance
systems of EBA CLEARING future-proof while maintaining and, where for payment infrastructures and their users, the topic of cyber security is
possible, further strengthening their value propositions. In particular, this part of the standing items on the agenda of the Board. This is also in ac-
means evolving their robust settlement function while providing new rails cordance with EBA CLEARING’s first and foremost objective to maintain a
for rich data transfer through new formats, such as ISO 20022. The road- stable and compliant processing environment for the reliable, efficient and
maps and timelines for the EURO1 ISO migration and the introduction of cost-effective day-to-day operation of its payment systems.
continuous gross settlement for STEP2 have been agreed in close consul-
tation with the respective user communities to minimise user impact and Looking forward, the combination of real-time payments and open banking
related risks. are expected to further open up the innovation space in the European and
global market, including new opportunities to explore more deeply the
In order to optimally support users in leveraging the benefits of these services layer linked to payment and accounts. In order to unlock these
changeovers, such as convergence of messaging standards, the Compa- opportunities for their customers, payment service providers will need to
ny has placed cross-service alignment at the top of its strategic agenda for rely on seamless end-to-end real-time processes. They may also require
the next few years. A central aim of this strategy is to provide users with additional infrastructure solutions, for instance a use case-agnostic infra-
tools enabling cross-service views and activities, so they can further im- structure layer for Request to Pay, in order to enable the pan-European
prove their intra-day liquidity management. implementation of this ‘missing link’ for leveraging instant payments and
other account-based payment instruments.
2018 also saw important changes kick in at governance level following the
decision at the Shareholders Meeting (SHM) 2017 to introduce identical At EBA CLEARING, we are eager to look into this and other opportunities
governance and user say arrangements for EURO1 and STEP2 to better as part of the Company’s ongoing development and based on the contin-
reflect the balance between the SIPS operated by EBA CLEARING. The ued fruitful exchange with our user community.
newly created EURO1 and STEP2 Business Committees took up their ac-
EBA CLEARING Annual Report 2018
tivities in Q1 2018 and have helped to effectively conduct the user consul- I take his opportunity to thank all our shareholders and users, my col-
tation processes around the future evolvement of these systems. leagues on the Board and all the professionals who have participated in
10 104 Chairman’s Statement
our committees, expert groups and task forces over the past year for their
In line with the approach agreed at the SHM 2018 for establishing compli- commitment and support. I would also like to thank the management and
ance with the new requirement of the Revised SIPS Regulation regarding staff of this Company and our technology partners for their dedication and
the Board composition of a SIPS operator, the Nomination and Govern- efforts as well as our Overseers for the continued constructive dialogue.
ance Committee (NGC) has paved the way for the recruitment of one Out- We look forward to continuing this successful journey with all of you in
side Director to complement the skills of the 15 independent directors 2019 and beyond.
serving on the Board. The Board has endorsed the resulting proposal of
the NGC for submission to the SHM 2019. Petia Niederländer
CEO’s
Statement
For EBA CLEARING, the year 2018 was marked both by great stability in
the daily operations of our pan-European payment systems and by major
reorientation and consultation work to chart the future course of the Com-
pany’s services in the light of significant industry change.
In the infrastructure arena, this change has translated into an overall push
for more granular data, (near) real-time liquidity settlement and a further
reinforcement of (cyber) security and resilience.
For our concrete context, this means that we have been coordinating the
ramp-up of RT1 together with the development of new functionality for the
service. We have also been exploring potential supporting elements for in-
stant payments, such as a pan-European Request to Pay solution. And,
last but not least, we have been heavily engaged in assessing – in co-op-
eration with our users and, in some cases, our critical service providers – In an industry that is going through substantial
how to adapt our systemically important payment systems and the under- transformation, EBA CLEARING has been success-
lying arrangements, so that they optimally support our users in enhancing
their value propositions for the new, digital, real-time reality and continue fully navigating through headwinds over the past
to meet evolving oversight requirements. year, thanks to the strong tailwinds that have
As in previous years, our prime focus for 2018 was put on resilient and supported our course: our highly committed Share-
efficient day-to-day service delivery. I am pleased to report that all our ser- holders and users, our long-standing technology
vices were operating reliably and smoothly during the period under report.
Altogether, they routinely processed well over 50 million payments per day. partners and our dedicated staff members.
The new kid on the block and leading pan-European infrastructure for
instant payments, RT1, ramped up nicely in its first year of operations,
passing the 10-million-transaction milestone in early January 2019 and
reaching a total of 20 million transactions in April 2019. Over 60% of the
Single Euro Payments Area are already addressable via the system and
EBA CLEARING Annual Report 2018
this reach should increase to over 90% in 2019 and 2020. RT1 has oper-
ated without any interruption, 24 x 7 x 365, since its launch. It is in its
fourth iteration after only 18 months, having added, among other features,
12 104 CEO’s statement
Last year was spent in intense design discussions and user consultations numerous resilience and crisis management exercises were conducted
to determine how best to adapt the system to the requirements of the Re- throughout the period under report. Preparations are ongoing for testing
vised SIPS Regulation. The future settlement model will meet the require- exercises in the context of TIBER-EU, the new Europe-wide framework for
ments of our large user community with minimal impact on liquidity and tests against cyber-attacks in the financial industry.
introduce new perspectives for the use of the system. It will undoubtedly
take some time to complete the roll-out, given the size of the community In an industry that is going through substantial transformation, EBA
as well as the overall implementation workload the industry is facing over CLEARING has been successfully navigating through headwinds over
the next few years. the past year, thanks to the strong tailwinds that have supported our
course. I want to take this opportunity to thank the key sources of
EURO1, providing liquidity savings, resilience and choice in euro large- these tailwinds: our highly committed Shareholders and users, our long-
value payments, continues to perform well and volumes are relatively sta- standing technology partners and our dedicated staff members. Like our
ble at around 200,000 per day. In 2018, the Company ran a series of work- Board, Business Committee, Expert and Working Group members, the
shops with the EURO1 Future Positioning Working Group, hashing out the EBA CLEARING staff consists of practitioners from all corners of Europe
key principles for EURO1 as it readies itself for the ISO 20022 migration, and beyond, who have come together to ensure the timely and reliable
together with TARGET2, which is scheduled for 2021. delivery of efficient and cost-effective pan-European payment infrastruc-
ture services.
The future value proposition was strongly supported by the EURO1 com-
munity during the subsequent user consultation. This includes aligning the Thanks to these tailwinds, the EBA CLEARING Company has managed to
service to the maximum extent possible with both TARGET2 and other cover a lot of ground in 2018 and early 2019 while it has, at the same time,
EBA CLEARING Services to allow easy switching between systems and a remained firmly positioned at the heart of European payments.
centralised liquidity management. There was consensus among the par-
ticipants to keep the core liquidity-saving features, which differentiate the We look forward to continuing this successful journey and track record
system. The chosen design approach will minimise development costs with the support and for the benefit of our users and the wider payments
and also allow rationalisation of system components. ecosystem.
The Company’s financials remain robust. Cash levels were increased in Hays Littlejohn
2018 to meet the liquidity requirements set for SIPS operators by the SIPS
Regulation. EBA CLEARING is in a position where the Company can
choose to finance some continuing investments itself, without recourse to
shareholders or bank credit lines.
EBA CLEARING Annual Report 2018
and risk management functions have been further strengthened and the
Company has intensified its activities as well as its co-operation with criti-
cal service providers on cyber resilience in particular.
31 December 2018.
The Company’s
STEP2 SDD B2B 85.21m 723bn 86.39m 759bn +1.39% +5.04% To this effect, the Company further intensified the dialogue with its service
users in 2018. In addition to the consultations with the two newly estab-
STEP2 CC 1.74bn 107bn 2.13bn 122bn +22.09% +14.60%
lished Business Committees and the different expert groups and working
RT1 0.144m 90m 9.73m 6bn N/A** N/A** groups, more than 30 user community meetings took place in 15 countries.
by 3.14% during the same period. Throughout 2018, EBA CLEARING man-
aged the settlement of 13.74 billion transactions across all services. This
18 104 Services: Introduction
While 2017 had been marked by the launch of a new infrastructure plat-
form, 2018 was shaped by extensive exchanges with the user communi-
ties on future changes to be brought to the EURO1/STEP1, STEP2 and
RT1 Services. The common objective was to further strengthen the value
proposition of each service and, at the same time, facilitate cross-service
views and activities at user level.
2 Evolution of EURO1 volumes, values and participation
Throughout 2018 and early 2019, EBA CLEARING maintained a close dia-
logue with service participants located in the United Kingdom (UK) on their
EURO1-related planning in connection with the UK’s preparations to leave
the European Union. By the end of March 2019, all EURO1 Participants
from the UK had transferred their participation to other EU locations in or-
der to ensure their continued participation in the system.
EURO1 Service TARGET2 as well as with the STEP2 and RT1 Services.
of the resulting work programme was ensuring maximal alignment with In parallel with the migration to the ISO 20022 standard, the Company
the evolution of TARGET2 in the context of the migration of large- plans to adapt the network topology for the EURO1 System, from the cur-
value payment systems to the ISO 20022 standard. The work programme rent Y-copy to the more generic V-shape, which will be used by TARGET2
20 104 EURO1 Service
is also aimed at optimally supporting the EURO1 users in their integration as well and will make EURO1 network agnostic.
of management and monitoring tasks across different services.
In line with participant requirements, EBA CLEARING further started prep- 4 System developments in 2018 and 2019
arations in 2018 for the roll-out of cross-service support tools as part of its
work programme. In June 2018, the Company presented a liquidity dash- A combined functional and technical annual release was implemented in
board demo providing an overview of the liquidity and position of partici- October 2018. As no functional changes had been proposed by the service
pants both in EURO1 and in RT1. The aim of such tools is to make it easier users, the release was limited in terms of scope and user impact.
for users to get an integrated view across all their EBA CLEARING service
activities and related intra-day liquidity positions. For 2019, a release is planned for November 2019, which will involve
changes at the level of the participant work station. The release will have a
The core functionality of the system, however, will not be affected by the limited impact on service users.
ongoing work programme, so that EURO1 will continue to provide the key
benefits as identified by its users: processing payments with immediate The 2019 release will further include the introduction of a liquidity dash-
finality in a highly liquidity-efficient, cost-effective and resilient way. board, which will provide additional intra-day liquidity monitoring facilities
for the banks. The dashboard will initially comprise information related to
EURO1 and is planned to integrate cross-service views covering RT1 and
EBA CLEARING Annual Report 2018
€ 221.1
billion
47
Participants
Close to
46
240,000 Sub-Participants
220,000 7,400
participant BICs and close to
12,000
200,000
EBA CLEARING Annual Report 2018
180,000
additional BICs reachable via
EURO1/STEP1 Participants
160,000
24 104 EURO1 Service
21 November 2000
A turn-key solution for single euro
payment processing
TECHNICAL
KEY FACTS AND FIGURES OPERATOR
STATUS: MARCH 2019
SWIFT
9,676
Close to EURO1 Banks act as
Settlement Banks
7,400 transactions
for STEP1 Participants
€ 1.4
billion Single euro payment
additional BICs reachable via
service for commercial
EURO1/STEP1 Participants
transactions, mainly
STEP1 Service
used by medium-sized
and smaller banks
PARTICIPATION
A turn-key solution for single euro payment processing 40 EVOLUTION OF AVERAGE DAILY
VOLUME OF PAYMENTS PROCESSED
The STEP1 Service offers a direct and cost-effective access to a highly Participants
14,000
4
resilient single euro payment processing platform. With its limited joining
and running costs as well as its wide reach, STEP1 provides a low-invest-
ment solution for the exchange of non-SEPA euro transactions with all key 12,000
payment banks operating in Europe. Sub-Participants
There was a decrease in the number of STEP1 Participants during the pe- 10,000
EBA CLEARING Annual Report 2018
The STEP1 transaction volume remained stable and the transaction val-
26 104 STEP1 Service
In line with the results of the annual STEP2 user consultation, EBA
CLEARING implemented new optional reports through a technical release
in April 2018 in order to further support participants in their liquidity man-
agement. A functional release put in place in November 2018 mostly fo-
cussed on EPC SCT Scheme Rulebook-related updates as well as on the
introduction of an additional debit notification file window for SDD Core at
7:00 CET.
As detailed in the new EPC SEPA Scheme Rulebooks, the STEP2 release
for 2019 will include a new set of inquiries and investigations for SCT and
the implementation of extended remittance information in replacement of
the related Additional Optional Service (AOS2). The release will also intro-
STEP2 Services duce a number of improvements to the direct participant work station and
the routing tables, in accordance with user needs as expressed in the re-
spective user consultation on these changes.
volumes and participant numbers in 2018 and early 2019. setting out the details of the proposed solution was kicked off in April 2019.
SCT
LEGAL BASIS
153
SDD CORE
35 million Direct
AVERAGE DAILY VOLUME
Over 3,900 Participants
30 million Reachable BICs
SCT
25 million SDD B2B SDD CORE
18
million
Over 3,300
113
transactions Direct
20 million
Participants
Reachable BICs
15 million
EBA CLEARING Annual Report 2018
25.4
10 million million interoperable with 15 other CSMs
98
transactions Direct
5 million
30 104 STEP2 Services
Participants
July 2018 this figure had nearly doubled to over 1,000 addressable pay-
ment service providers.
By the end of 2018, RT1 had expanded reach to over 2,300 payment ser-
vice providers from 12 European countries, which were addressable
through the 35 participants connected to the platform. Throughout the
year, the evolving RT1 reach corresponded to a coverage of close to 100%
of the account-servicing PSPs adhering to the EPC SCT Inst Scheme.
The November 2018 release introduced changes related to the EPC SCT
Inst Scheme Rulebook updates as well as SWIFTNet Instant connectivity,
in addition to the existing SIANet and EBICS based connectivity options,
and functionality enabling participants to use RT1 as their ‘Instructing Par-
ty’ in the TARGET Instant Payment Settlement (TIPS) Service. The latter
functionality allows participants to have a single interface for sending and
receiving transactions settling in RT1 or in TIPS.
To ensure the necessary agility for the further development of the system
during the instant payment ramp-up, EBA CLEARING has again sched-
uled two RT1 releases for implementation in 2019. The release to be put in 4 Contribution to industry debates
place in the second quarter of 2019 will further improve the tools support-
ing the day-to-day operations and support processes. The November EBA CLEARING has been fostering an open exchange on real-time pay-
2019 release will include changes stemming from the SCT Inst Scheme ment matters with other industry players and stakeholders, participating in
Rulebook and cover enhancements to the controlled go-live procedure, the TIPS Contact Group and, as an observer, in the AMI-Pay, the ECB’s
several participant workstation improvements and a new mechanism to advisory group on market infrastructures for payments. The Company also
exchange information on participants’ unavailability. contributed to other industry bodies and fora, such as the RTPG (the group
under the ISO 20022 standardisation body focussing on ISO messages
for real-time payments) and the Global Real Time / Instant Payment Group.
EBA CLEARING Annual Report 2018
€ 60.8
million each payment transaction.
The position of each partici-
pant is funded in central
bank funds.
1
OVERVIEW OF REACHABLE REACH PARTICIPATION
PSPS BY COUNTRY
37
RT1 extends reach to
3
4
over 2,300 payment
service providers Participants
5
2 from 13 EU countries,
2
2
1730 which are addressable via
the 37 participants connected
459 to the service
EBA CLEARING Annual Report 2018
25
1 79
36 104 RT1 Service
The service handled on average over 8.36 million transactions per day In 2018, as requested by the STEP2 CC user community and in order to
during 2018. STEP2 CC is currently used by seven participants for debit align the service with the STEP2 SEPA Services, EBA CLEARING intro-
38 104 STEP2 Card Clearing Service
card transactions under the German girocard scheme. In December 2018, duced the possibility for participants to use multiple network channels and
the daily average even reached 11.01 million transactions, representing a perform intraday connectivity switches in STEP2 CC.
growth of 28.86% compared to December 2017.
The 2019 release consists of improvements to the direct participant work
station and the routing tables, in line with the changes planned for the
STEP2 SEPA Services.
STEP2 Card LIVE DATE LEGAL BASIS
€ 486.1
million
PARTICIPATION
9
12 million
REACH
10 million
million Over 2,000 Reachable BICs.
transactions
8 million Full reach for the clearing of
pre-authorised girocard
6 million
transactions in Germany
40 104 STEP2 Card Clearing Service
14 October 2013
Alignment
SIA
KEY FACTS AND FIGURES
STATUS: MARCH 2019
LEGAL BASIS
600,000
PARTICIPATION 500,000
EBA CLEARING Annual Report 2018
33 400,000
Participants 300,000
43 104 SEDA
42 104 SEDA
200,000
2016 2017 2018 2019
Operations
EBA CLEARING’s Operations are spread across several sites located in 1 Clearing and settlement
different countries. They focus on the business administration and moni-
toring of the EURO1, STEP1, STEP2 SEPA, RT1, STEP2 CC and SEDA The systems operated by EBA CLEARING performed in line with the high-
Services. est resilience and security standards during the period under report.
Core activities include clearing and settlement, service monitoring, customer The service availability of all EBA CLEARING’s payment services was
support, crisis and incident management, data and statistical reporting, uninterrupted from January to December 2018. Furthermore, the validation
operational IT management, integration services for new products and and settlement of payment instructions were carried out smoothly on a
functionalities, integration of new participants as well as release and resil- daily basis, including peak volume days.
ience testing activities.
2 Incident management
EBA CLEARING Annual Report 2018
45 104 Operations
and adapted escalation processes are in place for all other EBA CLEARING
payment services.
Since 1 January 2019, EBA CLEARING’s incident reporting processes Customer support cases raised in 2018 and Q1 2019
have been aligned with the new major incident reporting framework for
operational and security incidents in retail payment systems, which is part
of the Eurosystem’s oversight framework for payment systems and applies 1,025 1,047 1,130 1,386 1,033 Grand Total
1,400
to the STEP2 SEPA, STEP2 CC and RT1 Services.
1,300
The incident management arrangements of EBA CLEARING are reviewed
1,200
and tested regularly to maintain best-of-breed services and processes.
359
1,100
1,000
3 Business continuity and resilience exercises
175 193 343 227 Test & Training
900
EBA CLEARING conducts a significant number of business continuity
800
exercises on an annual basis in co-operation with service participants and
key providers to strengthen the business resilience and preparedness of 700
all parties involved. A total of 54 testing exercises were successfully com- 279
600
pleted in 2018. For 2019, the business continuity and resilience testing
programme also consists of 54 exercises in total. 500
850 854 787 1,027 806 Live
400
200
EBA CLEARING’s customer support service provides a fully secured first
point of contact for user queries. Via an emergency helpdesk available 100
24/7/365, the service gives practical support and assists users with inquir-
0
ies related to their service participation and their operations.
Q1 2018 Q2 2018 Q3 2018 Q4 2018 Q1 2019
47 104 Operations
EBA CLEARING’s Contribution to scheme developments
Request to cess of defining a framework for a request to pay scheme. EBA CLEARING
contributes to the developments at scheme level as a member of the RTP
MSG and would ensure that an EBA CLEARING R2P infrastructure solu-
Pay Initiative tion would stay aligned with any scheme developments.
On 12 November 2018, EBA CLEARING announced the launch of a Re- Payee Request for goods / services Payer
quest to Pay (R2P) initiative with the set-up of an R2P Task force, involving
representatives from 30 user institutions from 14 European countries.
Together with this task force, EBA CLEARING delivered a blueprint for a
pan-European R2P infrastructure solution. Request to pay
R2P scope
Payee- Payer-
The blueprint sets forth the idea of developing an infrastructure solution PSP PSP
that would allow a harmonised and managed exchange of request to
pay messages at a pan-European level. This infrastructure layer should be Response
able to support different solutions and services as required for various use
cases.
Payment SCT or SCTInst
The blueprint was made available to the EBA CLEARING user community
for user consultation in April 2019. Based on this consultation and interest
expressed by users, the EBA CLEARING Board will decide on the devel-
opment of the R2P infrastructure solution, which could be implemented by
the end of 2020.
Legal, Regulatory During 2018, the following dedicated oversight assessments were con-
ducted:
release
1 Oversight of the SIPS operated by EBA CLEARING
During the period under report, the Company maintained the annual calen-
In August 2014, the Governing Council of the ECB identified the EURO1 dar and plan for regular review processes in line with the requirements of
and STEP2-T Systems as Systemically Important Payment Systems (SIPS) the SIPS Regulation. The progress of the required reviews is tracked
50 104 Legal, Regulatory and Compliance
With respect to the continuous oversight cycle for EURO1 and STEP2-T
in 2018, the Company was advised of planned oversight activities for 2018
at the beginning of the year.
The Revised SIPS Regulation of 3 November 2017 was published in the 2 Oversight of the STEP2 CC system operated
Official Journal (OJ) of the EU on 16 November 2017 and entered into force by EBA CLEARING
on 6 December 2017 (20 days after publication in the OJ). The Revised
SIPS Regulation foresaw a one-year transition period for compliance by During the reporting period, periodic formal oversight meetings took place
SIPS Operators with the changed or new requirements (i.e. 6 December between Deutsche Bundesbank, the ECB and EBA CLEARING.
2018), save that for compliance with the new requirements regarding
liquidity risk and credit risk an 18-month transition period was foreseen Upcoming changes in relation to the STEP2 CC system are advised to
(i.e. 6 June 2019). Deutsche Bundesbank in view of a classification to determine whether
changes would attract a dedicated oversight assessment. As no changes
The main areas of focus for EBA CLEARING as SIPS Operator of the to the STEP2 CC System were scheduled or carried out during the report-
EURO1 and STEP2-T Systems in view of compliance with the Revised ing period, no change assessments were necessary.
SIPS Regulation relate to governance, liquidity and credit risk and tiering
risk (i.e. identification and monitoring of material dependencies between
participants and entities that are not bound by the rules of the SIPS). In 3 Oversight of the RT1 system operated
addition, the new Cyber Resilience Oversight Expectations (CROE) issued by EBA CLEARING
by the ECB in December 2018 have become part of the requirements on
cyber resilience of the SIPS Regulation. A separate oversight assessment In May 2017, the ECB notified EBA CLEARING of the decision of the
was carried out in relation to those (see also below section on cyber resil- Governing Council of the ECB to assign oversight competence for EBA
ience). CLEARING’s new instant payment system, RT1, to the ECB. The ECB co-
operates with the Eurosystem central banks on these activities.
In the context of these revised SIPS requirements, notably for the credit
and liquidity risks, EBA CLEARING conducted an assessment of the new RT1 has been classified as Other Retail Payment System (ORPS) as per
obligations in 2018 and took the opportunity to also assess the evolution the revised Eurosystem Oversight Framework for Retail Payment Systems
of the STEP2-T design, in particular with regard to the settlement model. (RPSs). Since 2018, regular formal oversight meetings have taken place
The Company thus carried out a user consultation on this topic in the first between the ECB and EBA CLEARING in relation to RT1 oversight.
half of the year. In parallel to this consultation process, exchanges with the
Overseer took place on the proposed way forward. In June 2018, the ECB completed the oversight assessment of RT1 against
the CPMI-IOSCO Principles for Financial Market Infrastructures (PFMIs)
Furthermore, EBA CLEARING carried out an assessment of its govern- of the Committee on Payments and Market Infrastructures (CPMI) and the
ance structure in 2018. This assessment concluded that all members of Board of the International Organisation of Securities Commissions (IOSCO)
the EBA CLEARING Board are independent directors. Nevertheless, and applicable to ORPS, as outlined in the revised Eurosystem oversight frame-
in line with the mandate by the Shareholders Meeting of 11 June 2018, work for RPSs. During 2018, actions were taken and discussions with
EBA CLEARING has also taken the opportunity to further strengthen its the Overseer were held by EBA CLEARING to address recommendations
Board profile by including an ‘Outside Director’. The Outside Director will from the ECB. The approach to the recommendations is being followed up
bring a complementary skillset to the Board. in the context of the continuous oversight activities during 2019.
Finally, regarding tiering risks, EBA CLEARING has carried out a tiering During 2018, the following dedicated oversight assessments were com-
analysis for participants in both the EURO1 and STEP2-T Systems. The pleted:
assessment of material dependencies and the evaluation of risks arising
from tiered participation in these systems have revealed no relevant risk • a comprehensive oversight assessment of RT1 against compliance with
52 104 Legal, Regulatory and Compliance
In parallel, on 2 May 2018, the ECB published the European framework for
Threat Intelligence-based Ethical Red Teaming (TIBER-EU), which is the 6 Public consultations
first Europe-wide framework for controlled and bespoke tests against
cyber-attacks in the financial industry. The TIBER-EU framework has been On 10 April 2018, the ECB launched a public consultation on the draft
designed for national and European authorities and entities that form the CROE. The reply by EBA CLEARING to the public consultation was sub-
core financial infrastructure, including entities with cross-border activities mitted on 5 June 2018.
that fall within the regulatory remit of several authorities.
Responses made by EBA CLEARING to public consultations are typically
EBA CLEARING’s SIPS fall under the scope of the TIBER-EU framework, available on the website of EBA CLEARING.
which is why the Company has been in dialogue with the Competent
Authority to plan the related exercises for EURO1 and STEP2-T.
On the occasion of the RT1 June 2018 release, the Legal Advisory Group
(LAG) met by conference call on 16 May 2018 to discuss and review the
changes proposed to the RT1 Rules and Regulations to introduce i.a. more
options for liquidity-serviced participants to choose from for managing
their liquidity.
The LAG was further informed of the changes made to the legal documen-
tation of STEP2 and RT1 made in view of the November 2018 releases to
the effect of introducing clarifications in relation to the EPC SEPA Credit
54 104 Legal, Regulatory and Compliance
1 Internal developments
Throughout the period under report, the Risk Management function was
duly sustained, as part of the ‘second line of defence’. It was assured that
all tools and methodologies were maintained in line with best industry
practice and oversight requirements. In addition, efforts continued to keep
the level of risk awareness and understanding high among the Company’s
executives and staff.
A regular dialogue took place with the Board Risk Committee (BRC) with a The work strands conducted to comply with the Guidance on Cyber Resil-
view to assessing and mitigating the Company’s top and newly emerging ience for Financial Market Infrastructures by the Committee on Payments
risks. and Market Infrastructures (CPMI), initially published in June 2016, were
finalised in 2018 with the delivery of a Cyber Resilience Framework based
on the National Institute of Standards and Technology (NIST) standard.
Dedicated cyber security-related activities
Following the publication in 2018 of the Cyber Resilience Oversight Expec-
Throughout 2018, cyber risk mitigation remained a prominent focus of the tations (CROE) for financial market infrastructures by the European Central
Risk Management function. In line with its rapid evolution, actionable Bank, EBA CLEARING undertook a comprehensive analysis of the require
threat intelligence was collected from multiple highly reputable sources ments as applicable to its systems. As the operator of two Systemically
supporting the Company’s Cyber Security Operations Centre (C-SOC) Important Payment Systems (SIPS), EBA CLEARING is expected to dem-
activities, which aim to provide both first- and second-line support in cyber- onstrate compliance with two of the levels of expectations (Evolving and
related matters. In addition, new cyber security-related initiatives were Advancing). The Company’s self-assessment against the relevant require-
coordinated with the Company’s critical service providers. ments was completed in the first quarter of 2019.
EBA CLEARING Annual Report 2018
Towards the end of 2018, EBA CLEARING’s Information Security Man- EBA CLEARING’s Internal Audit function was maintained in line with best
agement System was re-certified against the ISO/IEC 27001:2013 stand- practice and continued its mission as the ‘third line of defence’ within the
ard for another three-year period, until 2022. The re-certification confirmed Company during the period under report.
the Company’s continued compliance with the requirements of the stand-
ard, which is designed to ensure the selection of adequate and proportion- The Company’s audit strategy and planning for 2018 was established under
ate security controls that protect information assets of the Company and the guidance of the Audit and Finance Committee (AFC), with which an
give the necessary confidence to all interested parties. open dialogue on all audit-related matters was maintained throughout the
year. In line with the annual audit plan, various internal and external audits
Throughout the period under report, the Company’s Information Security were completed in 2018 as scheduled.
EBA CLEARING Annual Report 2018
information and cyber security risk awareness, culture, and controls. suring.
59 104 Internal Audit
Corporate
Governance • Effective 18 September 2018, the Board, upon proposal by the Nomina-
tion and Governance Committee, co-opted Niklas Lemberg as Board
member to fill the vacancy following the appointment of Petia Nieder-
länder as EBA CLEARING Chairman.
1 Board of directors
• Effective 18 December 2018, the Board, upon proposal by the Nomina-
a Board composition tion and Governance Committee, co-opted Christof Hofmann as Board
member to fill the vacancy following the resignation of Christian Wester-
The Company’s by-laws, as amended with effect as of 30 November 2018, haus.
provide that the Company is managed by a Board composed of not more
than seventeen (17) members including the Chairman, the Deputy Chair- • Effective 24 December 2018, the Board, upon proposal by the Nomina-
man and up to two (2) but not less than one (1) Outside Director who are tion and Governance Committee, co-opted Michele Olin as Board mem-
appointed intuitu personae by the Shareholders Meeting for a renewable ber to fill the vacancy following the resignation of Peter Vance.
three-year term.
EBA CLEARING Annual Report 2018
The appointment of the Board members co-opted by the Board will be sub-
60 104 Corporate Governance
Since the Shareholders Meeting on 11 June 2018, during which Petia mitted for ratification to this Annual Ordinary Shareholders Meeting.
Niederländer was elected as Chairman in replacement of Erkki Poutiainen
for the remainder of his term of office, and five Board members were elect- EBA CLEARING has currently 49 shareholders, each holding one share of
ed for a three-year term of office, the changes to the membership of the EBA CLEARING and having one vote at the Shareholders Meeting. All the
Board have been the following: current members of the Board are employees or officers of EBA CLEARING
shareholders, and are considered to be independent since none of the
shareholders have a controlling stake in EBA CLEARING.
Board members, other than the Outside Director(s), shall be elected from Overview of Board members
among employees or officers of the shareholders. The policy for the nomina- who held office in 2018 – 2019
tion of candidates to the EBA CLEARING Board of Directors (the Board
Nomination Policy) sets the framework for the Board members’ nomination
process. The Nomination and Governance Committee of the Board main-
tains a Board target profile to track the desirable collective attributes for
ensuring an appropriate mix of technical skills, knowledge and experience
on the Board, and assists the Board in ensuring that the Board’s composi-
tion allows the Board to fulfil its respective roles and responsibilities.
James Barclay Jutta Cammaer Daniela Dell’Arciprete Petia Niederländer Niklas Lemberg
JP Morgan Chase Bank N.A. KBC Bank N.V. Intesa Sanpaolo S.p.A. ERSTE Group Bank AG Nordea Bank Abp
Executive Director, Global General Manager Payments Head of Corporate and Financial Head of Group Retail & Head of Payment Industry
Market Infrastructures for Corporates Institutions Sales and Network Corporate Operations Appointed on 18.09.2018
Management
Appointed on 19.06.2017 Appointed on 19.06.2017 Appointed on 06.06.2016 End of term of office: SHM 2019
End of term of office: SHM 2020 End of term of office: SHM 2020 Appointed on 11.06.2018 End of term of office: SHM 2019 Chair of the STEP2 Business
End of term of office: SHM 2021 Chair of the STEP2 Business Committee since 01.01.2019
Chair of the Board Risk Committee
Committee since 24.12.2018
Kirstine Nilsson Edström Christian Rhino Luis Pedro Simões Raouf Soussi Laghmich Fabio Stragiotto
Swedbank AB (publ) Commerzbank AG Novo Banco S.A. BBVA S.A. UniCredit S.p.A.
Head of Business Infrastructure Divisional Board Member Co-Head of Payment Operations Head of Global Product for Vice President – Client Access
GCP & GCM Group Banking Operations Treasury Solutions Italy and Payment Products
Appointed on 11.06.2018
Global Transaction Banking
Appointed on 11.06.2018 Appointed on 06.06.2016 End of term of office: SHM 2021 Appointed on 11.06.2018
End of term of office: SHM 2021 End of term of office: End of term of office: SHM 2021 Appointed on 19.06.2017
SHM 2019 End of term of office: SHM 2020
EBA CLEARING Annual Report 2018
Frantz Teissèdre Peter Vance Michele Olin Christian Westerhaus Christof Hofmann Narinda You
Société Générale S.A. Allied Irish Banks, p.l.c. Allied Irish Banks, p.l.c. Deutsche Bank AG Deutsche Bank AG Crédit Agricole S.A.
Head of Interbank Relationships Head of Banking Operations & Head of Payments Head of Cash Clearing Products Global Head of Payments and Payment Services
Customer Services RCB Digital Products and GTB Cash Management Collection Products, Head of Strategy and
Appointed on 06.06.2016
Payments Corporate Cash Management Interbank Relations
End of term of office: SHM 2019 Appointed on 11.06.2018 End of term of office: 18.12.2018
Chair of the EURO1 Business End of term of office: 14.11.2018 Appointed on 24.12.2018 Chair of the Board Risk Appointed on 18.12.2018 Appointed on 19.06.2017
Committee since 01.01.2019 Chair of the EURO1 Business End of term of office: SHM 2021 Committee until 18.12.2018 End of term of office: SHM 2020 End of term of office: SHM 2020
Committee until 14.11.2018
EBA CLEARING Board committee 2 Board Committees
membership in 2018
a Introduction
Audit and Board Risk Strategy and Nomination Remuneration In 2018, the Board was supported by five Board Committees, composed of
Finance Committee Policy and Governance Committee Board members, in carrying out its functions: the Audit and Finance Com-
Committee Committee Committee mittee, the Risk Committee, the Strategy and Policy Committee, the Nomi-
nation and Governance Committee, and the Remuneration Committee.
Number of 6 4 5 7 4
meetings in 2018
b Audit and Finance Committee
Petia Niederländer Observer Observer Chair Chair
(since 11.06.2018) (since 11.06.2018) (since 11.06.2018) (since 11.06.2018) The Audit and Finance Committee (AFC) assists the Board in fulfilling its
oversight responsibilities for setting out the policy and the guidelines for the
Erkki Poutiainen Observer Observer Chair Chair
internal and external audit of the Company, for defining and monitoring the
(until 11.06.2018) (until 11.06.2018) (until 11.06.2018) (until 11.06.2018)
internal audit requirements and the tasks entrusted to the external auditors,
Robert Heisterborg Member Chair Member and for reviewing and monitoring the financial situation of the Company.
Jutta Cammaer Member • examines the annual and interim statutory and consolidated financial
(since 24.12.2018) statements of EBA CLEARING submitted by the Company’s manage-
ment, prior to their examination by the Board. As part of these tasks,
Daniela Chair
the committee reviews and analyses the budget variance, forecast and
Dell’Arciprete (since 24.12.2018)
financial statements;
Christof Hofmann Member
(since 01.04.2019) • gives its opinion on the development of the internal audit function, deter-
mines the internal audit plan and receives a summary of the internal audit
Niklas Lemberg
reports on a regular basis;
Kirstine Nilsson Member
Edström • reviews the audit findings of the Company’s statutory auditors and the
report from the statutory auditors on key audit findings.
Michele Olin
and for audit, including analysis against budget to adapt the 2018 fore-
Christian Chair Member Member cast, cashflow projections and outlook;
Westerhaus (until 18.12.2018) (until 18.12.2018) (until 18.12.2018)
• examination of the statutory and consolidated financial statements for
Narinda You Member Member
2018 in view of their closing in 2019 and review of the 2019 budget and
capital investment plan;
• review of the internal audit 2018 activity report and approval of the inter-
nal audit plan for 2019;
• review of AFC Terms of Reference for subsequent endorsement by the In detail, the SPC closely accompanied the evolution of RT1 functionality,
Board; which was implemented through four releases between November 2017
and May 2019. The Committee also gave input to and guidance on the
• examination and approval of a project to upgrade, standardise and im- user consultation process for STEP2 and related considerations on chang-
prove the Company’s financial toolset and processes; es to the STEP2 settlement model in light of revised requirements of the
SIPS Regulation. The SPC further provided direction on the way forward
• ensuring that the Highly Liquid Assets (HLA) reserve was at the appro- regarding the ISO migration and the future positioning of EURO1.
priate level at all times in line with SIPS requirements.
Other relevant strategic topics on which the SPC provided guidance includ-
ed considerations around cross-service alignment as well as the launch and
c Board Risk Committee development of a pan-European Request to Pay (R2P) initiative.
The Board Risk Committee (BRC) assists the Board in fulfilling its over- The SPC also closely followed and was consulted on oversight develop-
sight responsibilities with regards to the risk tolerance of the Company and ments of strategic relevance. The Committee further engaged in consid-
the risk management and compliance frameworks. erations around the general future positioning of the Company’s services
based on a close monitoring of relevant developments in the European and
The BRC is composed of Board members designated by the Board; meet- global payments ecosystem.
ings of the BRC are attended by the Company’s Chief Executive Officer,
the Chief Risk Officer and the General Counsel.
e Nomination and Governance Committee
Four regular BRC meetings took place in 2018. One additional meeting
was dedicated to the financial market infrastructure cyber threat land- The Nomination and Governance Committee (NGC) assists the Board in
scape, its evolution and the state of the Company’s Cyber Resilience implementing and reviewing the nomination policy and process for Board
Framework. The session was attended by the full Board. members and the policy and methodology for Board and individual Board
member evaluation. The NGC further monitors the effectiveness of the
In line with its mission, the BRC also monitored the maintenance of the Company’s governance framework. During 2018, seven meetings of the
Risk Management Framework and the follow-up of outstanding risks in NGC were held.
accordance with the Company’s Risk Treatment Plan. The BRC received
reports on the top actual and emerging risks and monitored the follow-up The major topics addressed by the NGC in 2018 included (i) changes to
actions relating thereto. the composition of the Board and its Committees in relation to the replace-
ment of the Chairman and of some Board members, (ii) a change to the
Cyber-related risks and oversight expectations remained prominently on by-laws of EBA CLEARING in line with the approach agreed at the Share-
the agenda of the Committee throughout 2018. holders Meeting on 11 June 2018 for establishing compliance with the new
requirement of the Revised SIPS Regulation regarding the Board composi-
tion of a SIPS operator, and (iii) the search for an Outside Director.
d Strategy and Policy Committee
In relation to these high-level topics, the NGC dealt with the following
The Strategy and Policy Committee (SPC) addresses the longer-term tasks in 2018:
planning for the positioning and the development of the Company, its pay-
ment infrastructure systems and solutions as well as potential new service • nomination process for a replacing Chairman;
offerings. In 2018, the Committee met five times.
• nomination process for the co-optation of replacing Board members;
EBA CLEARING Annual Report 2018
In 2018 and early 2019, the SPC provided guidance on three focal areas:
68 104 Corporate Governance
• development of RT1 in line with growing user needs, in particular to foster • changes in the composition of the Board Risk Committee and Strategy
RT1 adoption; and Policy Committee;
• launch and progress of an initiative to work on a pan-European Request • assessment of options and preparations of changes to corporate
to Pay solution. governance documents including the Board nomination policy and the
Company by-laws to establish compliance with the requirement of the 3 User say governance
Revised SIPS Regulation to include an ‘independent director’ within the
meaning as defined in the Revised SIPS Regulation; a Relations with users
• assessment of options and proposal for a Remuneration Policy for the In order to ensure that all types of users are considered in the design and
Board of Directors in preparation of the appointment of an Outside Director; evolution of its systems and offerings, the Company maintains a broad range
of communication channels with its (current and potential) users and other
• assessment of options for selecting candidates to the position of Out- stakeholders. There are regular country or regional user meetings with the
side Director participation of all respective users and attended by EBA CLEARING execu-
tives, where ongoing activities and projects are discussed and feedback is
registered. In the context of specific projects, steering groups or task forces
The NGC carried out a significant number of other tasks in 2018, including: may be created to ensure efficient liaison throughout the project or initiative.
• review of the outcome and guidance on follow-ups of the annual Board Furthermore, the Company organises individual user visits, and when ap-
performance evaluation for 2017; propriate or desired, roadshows and information campaigns.
• the review of the outcome of the Board performance evaluation for 2018 c User consultations for systems and services other than
EURO1 and STEP2-T
• the screening of the candidacies for the position of Outside Director
The Company consults its users, communities of users and other stake-
• accompanying the nomination process for the Outside Director as well holders (as required) in the event of changes that affect the Company’s
as for the candidates to fill one third of the seats on the Board, including services and/or service platforms. The consultation process on changes
the positions of Chairman and Deputy Chairman, which will become va- is, in principle, composed of the following steps: submission of proposals
cant at the end of the Shareholders Meeting on 17 June 2019. by or to the relevant stakeholders; evaluation of the proposals by the Com-
pany, including technical feasibility and cost analysis; and submission of a
EBA CLEARING Annual Report 2018
The Board is further assisted by the Remuneration Committee in establish- The adaptations to the governance arrangements for the SIPS operated
ing a sound remuneration framework, which fosters high performance and by EBA CLEARING do not impair the flexibility required to accommodate
motivation of staff members in line with the resourcing strategy and the specificities in relation to given services or initiatives as well as evolving
interests of the Company. The Remuneration Committee has delegated scopes of activity, which may warrant different models for consultation
powers from the Board in these matters. During 2018, four meetings of the and decision-making. The user say governance for the different systems
Remuneration Committee were held. and services is designed to effectively respond to the stakeholders’ needs
for efficient organisation of the different groups and their remit.
To allow the Board and management to take account of the interests of the 4 Other stakeholders
users in its decision-making in relation to the design, rules, overall strategy
and major changes to the various systems and services, the Company Potential users and other stakeholders
has, apart from the Business Committees established for the SIPS oper-
ated by the Company, established the following user groups: Apart from the consultation and coordination with user and expert groups
mentioned above, the Company organises roadshows and information
i RT1 Working Group sessions for wider stakeholder groups when and where relevant. Consulta-
Its objective is to serve as a forum in which direct participants in the RT1 tions may also take place on an ad-hoc basis.
System can discuss and provide feedback on the development, change
management and evolution of the RT1 Service, as well as related initia-
tives. Overseer and policy stakeholders
ii STEP2 CC Group The Company’s mission underpins its resolve to contribute to industry ini-
Its objective is to serve as a forum in which direct participants in the STEP2 tiatives and to engage with industry and policy stakeholders, including
CC Service can discuss and provide feedback on the development, regulators, overseers, the European Payments Council, standardisation
change management and evolution of the service. bodies, and the constituencies entrusted with policy setting.
Expert Groups provide expert advice for all systems for which a Business
EBA CLEARING Annual Report 2018
The following changes occurred in 2018 and in the first few months of
2019 as far as EBA CLEARING share capital and EBA CLEARING Share-
holders are concerned:
Janina Grönholm Eva Herskovicova Katja Heyder • With effect as of 9 April 2018, Citibank Europe Plc became EURO1 Par-
Baltic Countries, Czech Republic, Hungary, Austria, Bulgaria, Croatia, Cyprus, ticipant and EBA CLEARING Shareholder in replacement of Citibank NA.
Finland and Poland Slovakia and Slovenia Germany, Greece, Liechtenstein,
Luxembourg, Malta, Romania,
Spain and Switzerland • With effect as of 1 October 2018, Nordea Bank Abp replaced Nordea
Bank AB (publ), Finnish Branch, as EURO1 Participant and as EBA
CLEARING Shareholder.
André Vink
The Netherlands
The SIPS Regulation implements the Principles for Financial Market Infra-
structures (PFMIs), issued by CPMI and IOSCO in 2012, and applies to
Systemically Important Payment Systems (SIPS) in the Eurozone. The
system’s importance is determined by an appraisal of financial impact, de-
Oversight of the gree of market penetration, a system’s cross-border activity and whether
the system provides settlement for other financial market infrastructures.
No distinction is made for the application of the Regulation between large-
EBA CLEARING ing Council of the European Central Bank (ECB) as Systemically Important
Payment Systems under the SIPS Regulation.
The ECB Regulation (EU 795/2014) on Oversight Requirements for System fore, EBA CLEARING is in the unique position of being the SIPS Operator
ically Important Payment Systems (the SIPS Regulation) amended in 2017 of two SIPS.
by EU Regulation 2017/2094 (the revised SIPS Regulation), covers both
large-value and retail payment systems of systemic importance, whether
operated by Eurosystem national central banks or private entities.
2 Dialogue with the Overseer and oversight assessments
for SIPS
Any change to the SIPS and ORPS that EBA CLEARING operates are
subject to classification. In accordance to this classification, the Overseer
determines whether changes to the systems require an ex ante or an ex
post facto oversight assessment. The result of these change assessments
is formally advised to EBA CLEARING by the Overseer. The Overseer
further conducts comprehensive oversight assessments of the systems it
oversees with a regular frequency.
The ECB publishes on its website the list of systems that fall under the In accordance with the Revised Oversight Framework for Retail Payment
SIPS Regulation and of other classified systems. In line with the Revised Systems of the Eurosystem, the PFMIs and the Oversight expectations for
Oversight Framework for Retail Payment Systems of the Eurosystem links between retail payment systems (OELRPS) form the core of the
and with reference to the most current published list of payment systems standards to be applied to retail payment systems other than SIRPS by
according to the Eurosystem’s payment system classification, a distinction the Eurosystem national central banks. Nine principles of the PFMIs apply
is made in relation to retail payment systems between: to both PIRPS and ORPS, of which six with the same level of strictness
and three with a slight differentiation (namely Governance, Participant De-
• Systemically Important Retail Payment Systems (SIRPS) fault Rules and Procedures, and Access and Participation Requirements).
• Prominently Important Retail Payment Systems (PIRPS) and Formal classification of STEP2 CC as Other Retail Payment System is
based on the market share of the system at euro area country level.
• Other Retail Payment Systems (ORPS)
78 104 Oversight of the Payment Systems
ment System (ESIRPS). STEP2 CC system are advised to Deutsche Bundesbank in view of a
classification to determine whether changes would attract a dedicated
oversight assessment.
4 Oversight of RT1
The primary oversight responsibility for RT1 has been assigned to the ECB,
with participation by Eurosystem central banks.
Prior to the go-live in November 2017, the RT1 System was classified as
Other Retail Payment System and to date, this classification remains appli-
cable. Therefore, the oversight standards for ORPS are applicable to RT1.
Since 2018, regular formal oversight meetings take place between the ECB
and EBA CLEARING. Upcoming changes in relation to the RT1 System are
advised to the ECB in view of a classification to determine whether the
changes would attract an ex ante or ex post facto assessment from the
Overseer.
In April 2019, PRETA launched the onboarding process for its OBE direc-
tory, a pan-European, centralised and machine-readable repository for en-
EBA CLEARING Annual Report 2018
EBA CLEARING completed the fiscal year 2018 with a positive net result
before consolidation of EUR 3.2 M.
The Company further improved its cash position in 2018 to EUR 16.1 M
(compared to EUR 14.2 M in 2017) and continues to fulfil its obligations to
cover General Business Risk, as foreseen under the SIPS Regulation. The
2018 results testify to EBA CLEARING’s continuing solid business perfor-
mance, which involved a further decrease of the Company’s average costs
per unit.
Overview of revenues
Revenues 67,430 69,387 1,957 The transaction fee revenues amounted to EUR 47.9 M, which is an in-
crease of EUR 1,207 K compared to 2017 (+2.5%). This increase came
from a solid traffic growth in the STEP2 SEPA and CC Services (+6.6%),
increase of EUR 272 K compared to 2017. Other fees are one-off adminis-
trative fees related to provisioning, joining and exit fees.
The direct costs increased by EUR 3 M (+6.9% vs 2017), totalling EUR 46.8 M. The operating costs increased by EUR 1.1 M (+6.8 % vs 2017), totalling EUR 17.1 M.
Profit & Loss Statement 2017 2018 2018 vs 2017 Profit & Loss Statement 2017 2018 2018 vs 2017
Operating charges 40,183 42,963 2,780 Human resources 10,956 11,176 220
The other charges amounted to EUR 3.8 M, which corresponds to an in- In accordance with its continuing efforts to keep the development of its
crease by EUR 253 K, mainly due to the start of depreciation of the RT1 operating costs in line with business growth, the Company, where possi-
platform. ble, covered specialised resourcing needs in support areas through con-
sultancies. This led to a slower growth in full-time staff than expected.
Gross margin
Overview of EBA CLEARING resources
The gross margin decreased by EUR 1.1 M (– 4.6% vs 2017), totalling EUR 22.6 M.
the first full year of operations of the RT1 Service as well as the above-men-
tioned traffic and participation growth in the respective STEP2 Services.
Overview from gross margin to net result Statutory balance sheet
The cash flow generated by the Company’s activities in 2018 was healthy
at EUR 5.9 M (vs EUR 6.5 M in 2017).
Cash Flow Statement 2017 2018 2018 vs 2017 Payables 19,117 19,701 584
Accounts receivable as of 31 December 2018, amounting to EUR 18 M, may The equity position of EBA CLEARING before consolidation with PRETA
be split by due date as follows: reached EUR 27.9 M with a net result of EUR 3.2 M.
Since the creation of the Company, no dividends have been paid to Share-
Due in Due in Due in Due in Due before Total holders. It is proposed to maintain this policy and allocate the result of the
January 2019 December 2018 November 2018 October 2018 October 2018
period under report to retained earnings.
Number of invoices
301 8 2 15 3 329
Customers
in K EUR 15,819 76 1 407 7 16,310
Other receivables
in K EUR 1,744 – – – – 1,744
Receivables / Revenues
25% 0 % 0 % 1 % 0 % 26 %
Payables
Number of invoices
54 76 6 3 1 140
88 104 Financial Situation: Statutory Accounts
Other payables
EBA CLEARING Annual Report 2018
ABN AMRO Bank N.V. ERSTE Group Bank AG ABANCA Corporación Bancaria S.A. STEP1 Bank
Allied Irish Banks Plc Eurobank Ergasias S.A. ABN AMRO Bank N.V. EURO1 Participant
Alpha Bank A.E. HSBC France Allied Irish Banks, p.l.c. EURO1 Participant
Banca Monte dei Paschi di Siena ING Bank N.V. Allied Irish Bank Plc (GB) EURO1 Sub-Participant
S.p.A. Intesa Sanpaolo S.p.A. First Trust Bank EURO1 Sub-Participant
Banco Bilbao Vizcaya Argentaria JPMorgan Chase Bank N.A. Aktia Bank PLC STEP1 Bank
S.A. KBC Bank N.V. Allgemeine Sparkasse Oberösterreich STEP1 Bank
Banco BPM S.p.A. Landesbank Baden-Württemberg Bank AG
Banco Comercial Português S.A. Landesbank Hessen-Thüringen Alpha Bank AE EURO1 Participant
Banco de Sabadell S.A. Girozentrale Banca del Fucino STEP1 Bank
Banco Santander S.A. MUFG Bank, Ltd. Banca di Imola S.p.A. STEP1 Bank
Bank of America N.A. National Bank of Greece S.A. Banca Monte dei Paschi di Siena S.p.A. EURO1 Participant
Banque et Caisse d’Epargne de National Westminster Bank Plc Banca Widiba SpA EURO1 Sub-Participant
l’Etat, Luxembourg Nordea Bank Abp MPS Leasing & Factoring S.p.A. EURO1 Sub-Participant
Banque Fédérative du Crédit Novo Banco, S.A. Banca Popolare del Lazio STEP1 Bank
Mutuel OP Corporate Bank Plc Banca Popolare di Sondrio STEP1 Bank
Banque Internationale á OTP Bank Plc. Banca Sella S.p.A. STEP1 Bank
Luxembourg S.A. Rabobank Nederland Banco BAI Europa SA STEP1 Bank
Barclays Bank Plc Raiffeisen Bank International AG Banco Bilbao Vizcaya Argentaria S.A. EURO1 Participant
BNP Paribas S.A. Skandinaviska Enskilda Banken AB Banco BPM S.p.A. EURO1 Participant
BPCE Société Générale Banca Popolare di Milano S.p.A. EURO1 Sub-Participant
CaixaBank S.A. Standard Chartered Bank AG Banco Comercial Português S.A. EURO1 Participant
Citibank Europe Plc Svenska Handelsbanken AB Banco de Sabadell S.A. EURO1 Participant
Commerzbank AG Swedbank AB Banco Santander S.A. EURO1 Participant
Crédit Agricole S.A. UBS AG Banco Santander Totta, SA EURO1 Sub-Participant
Danske Bank A/S UniCredit S.p.A. Santander Consumer Bank AG EURO1 Sub-Participant
Deutsche Bank AG Santander UK Plc EURO1 Sub-Participant
DNB Bank ASA Bank für Tirol und Vorarlberg AG STEP1 Bank
DZ BANK AG Bank GPB International S.A. STEP1 Bank
Bank of Åland PLC STEP1 Bank
Bank of America N.A., Frankfurt branch EURO1 Participant
The Bank of New York Mellon, STEP1 Bank
Frankfurt Branch
Bankinter SA STEP1 Bank
EBA CLEARING Annual Report 2018
93 104 Appendices
Banque et Caisse d’Epargne de l’Etat EURO1 Participant Emirates NBD PJSC STEP1 Bank
Banque Internationale à Luxembourg S.A. EURO1 Participant ERSTE Group Bank AG EURO1 Participant
Banque Michel Inchauspé – BAMI STEP1 Bank Eurobank Ergasias S.A. EURO1 Participant
Banque Palatine STEP1 Bank Hellenic Bank Public Company Ltd. STEP1 Bank
Barclays Bank Ireland Plc, Frankfurt branch EURO1 Participant HSBC France EURO1 Participant
Berliner Sparkasse – Landesbank Berlin AG STEP1 Bank ICCREA Banca STEP1 Bank
BKS Bank AG STEP1 Bank ING Bank NV EURO1 Participant
BNP Paribas S.A. EURO1 Participant Bank Mendes Gans N.V. EURO1 Sub-Participant
Banca Nazionale del Lavoro S.p.A. EURO1 Sub-Participant ING Bank NV, France EURO1 Sub-Participant
BGL BNP Paribas EURO1 Sub-Participant ING Bank Śląski S.A. EURO1 Sub-Participant
BNP Paribas Fortis EURO1 Sub-Participant ING Belgium N.V./S.A EURO1 Sub-Participant
BPCE EURO1 Participant ING Luxembourg S.A. EURO1 Sub-Participant
BRED Banque Populaire EURO1 Sub-Participant Intesa Sanpaolo S.p.A. EURO1 Participant
NATIXIS EURO1 Sub-Participant Intesa Sanpaolo Bank Luxembourg S.A. EURO1 Sub-Participant
BPER Banca S.p.A. STEP1 Bank Joh. Berenberg, Gossler und Co. KG STEP1 Bank
CaixaBank S.A. EURO1 Participant J.P. Morgan AG EURO1 Participant
Caixa Central de Crédito Agrícola Mútuo STEP1 Bank J.P. Morgan Bank (Ireland) Plc EURO1 Sub-Participant
Cassa di Risparmio di Fermo S.p.A. STEP1 Bank J.P. Morgan Bank Luxembourg S.A. EURO1 Sub-Participant
Cassa di Risparmio di Ravenna S.p.A. STEP1 Bank KBC Bank N.V. EURO1 Participant
CECABANK, S.A. STEP1 Bank Kookmin Bank London Branch STEP1 Bank
Caja de Ahorros y Monte de Piedad STEP1 Sub-Participant La Banque Postale STEP1 Bank
de Ontinyent STEP1 Sub-Participant Caja Laboral Popular, Coop. de Crédito STEP1 Bank
Colonya Caixa Pollença Landesbank Hessen-Thüringen EURO1 Participant
Liberbank, S.A. STEP1 Sub-Participant Mashreq Bank psc STEP1 Bank
Unicaja Banco, S.A. STEP1 Sub-Participant MUFG Bank, Ltd., Paris branch EURO1 Participant
Citibank Europe Plc EURO1 Participant National Bank of Greece S.A. EURO1 Participant
Commerzbank AG EURO1 Participant National Westminster Bank Plc EURO1 Participant
Crédit Agricole S.A. EURO1 Participant National Westminster Bank Plc EURO1 Sub-Participant
CA-CIB – Crédit Agricole Corporate and EURO1 Sub-Participant Royal Bank of Scotland Plc EURO1 Sub-Participant
Investment Bank EURO1 Sub-Participant Nordea Bank Abp EURO1 Participant
Crédit Agricole CariParma SpA Oberbank AG STEP1 Bank
Crédit Agricole CariSpezia SpA EURO1 Sub-Participant OP Corporate Bank Plc EURO1 Participant
Crédit Agricole Friuladria SpA EURO1 Sub-Participant OTP Bank Plc. EURO1 Participant
Crédit Lyonnais EURO1 Sub-Participant Rabobank Nederland EURO1 Participant
Crédit Mutuel – CIC Banques EURO1 Participant Raiffeisen Bank International AG EURO1 Participant
Crédit Industriel et Commercial EURO1 Sub-Participant Raiffeisenlandesbank Oberösterreich AG STEP1 Bank
Crédit Mutuel Arkéa STEP1 Bank Raiffeisen-Landesbank Tirol AG STEP1 Bank
Credito Valtellinese STEP1 Bank SECB Swiss Euro Clearing Bank GmbH STEP1 Bank
Danske Bank A/S EURO1 Participant
Northern Bank Ltd EURO1 Sub-Participant
(trading as Danske Bank)
Deutsche Bank AG EURO1 Participant
EBA CLEARING Annual Report 2018
95 104 Appendices
Skandinaviska Enskilda Banken EURO1 Participant Appendix 3
AS SEB Pank, Estonia EURO1 Sub-Participant List of Direct Participants in STEP2-T
SEB Banka, Latvia EURO1 Sub-Participant Status: 31 May 2019
Skandinaviska Enskilda Banken S.A., EURO1 Sub-Participant
Luxembourg
Skandinaviska Enskilda Banken, EURO1 Sub-Participant
Denmark
Société Générale EURO1 Participant
Crédit du Nord EURO1 Sub-Participant
STEP2 SCT Banque de Luxembourg DB Privat- und Firmenkundenbank
Banque Eni S.A. AG (Postbank)
Sparekassen Sjælland STEP1 Bank
ABN AMRO Bank N.V. Banque et Caisse d’Epargne De Nederlandsche Bank N.V.
Standard Chartered Bank AG EURO1 Participant
Adyen B.V. de l’Etat DEPObank – Banca Depositaria
Svenska Handelsbanken EURO1 Participant
Aktia Bank Plc Banque Internationale Italiana SpA
Handelsbanken, Denmark EURO1 Sub-Participant
Allied Irish Banks, Plc à Luxembourg S.A. Deutsche Bank AG
Handelsbanken, Norway EURO1 Sub-Participant
Alpha Bank Cyprus Ltd Barclays Bank Ireland Plc Deutsche Bundesbank
Swedbank AB (publ.) EURO1 Participant
Arbejdernes Landsbank A/S Barclays Bank Plc DNB Bank ASA
Swedbank AB, Lithuania EURO1 Sub-Participant
AS LHV Pank Barclays Bank UK Plc DZ BANK AG
Swedbank AS, Estonia EURO1 Sub-Participant
AS SEB Pank Belfius Bank SA/NV Elavon Financial Services Limited
Swedbank AS, Latvia EURO1 Sub-Participant
Banca Carige SpA BGL BNP Paribas ERSTE Group Bank AG
UBS Europe SE, Germany EURO1 Participant
Banca d’Italia BNP Paribas Fortis SA/NV First Investment Bank AD
UniCredit S.p.A. EURO1 Participant
Banca Monte dei Paschi BNP Paribas S.A. Hellenic Bank Public Company Ltd
UniCredit Bank AG (Hypovereinsbank) EURO1 Sub-Participant
di Siena SpA Bonum Bank Plc HSBC Bank Plc
UniCredit Bank Austria AG EURO1 Sub-Participant
Banca Popolare di Sondrio SCPA BPCE HSBC France
Banca Sella Holding SpA bpost SA de droit public HSBC UK Bank Plc
Banco Bilbao Vizcaya bpost Bank N.V.-S.A. ICCREA Banca SpA – Istituto
Argentaria S.A. BRED Banque Populaire Centrale del Credito Coop.
Banco BPI S.A. Bunq B.V. ING Bank NV
Banco BPM SpA Caixa Central de Crédito ING Belgium NV-SA
Banco Comercial Português S.A. Agrícola Mútuo ING Luxembourg SA
Banco Cooperativo Caixa Geral de Depósitos S.A. Intesa Sanpaolo SpA
Banco de España CaixaBank S.A. J.P. Morgan AG
Banco de Sabadell S.A. Cassa Centrale Banca – Credito Jyske Bank AS
Banco Popular Español S.A. Cooperativo Italiano SpA KBC Bank N.V.
Banco Santander S.A. Cassa Depositi e Prestiti SpA Klarna Bank AB (publ)
Banco Santander Totta S.A. CECABANK S.A. Københavns Andelskasse
Bank of Aland Plc Central Bank of Savings Banks La Banque Postale
Bank of America, NA, Finland Plc Lån & Spar Bank A/S
Frankfurt Branch Citibank Europe Plc Landesbank Baden-Württemberg
Bank of Cyprus Public Company Ltd Clydesdale Bank Plc Landesbank Hessen-Thüringen
Bank of Greece S.A. Commerzbank AG (HELABA)
Bank of Ireland Crédit Agricole S.A. Latvijas Banka
Bank of Slovenia – Banka Slovenije Crédit Agricole Italia SpA Lietuvos Bankas – Bank of Lithuania
EBA CLEARING Annual Report 2018
97 104 Appendices
MUFG Bank, Ltd., Paris Branch STEP2 SDD CORE Caixa Geral de Depósitos S.A. MUFG Bank, Ltd, Paris Branch Banco Santander Totta S.A. HSBC France
Narodowy Bank Polski – National CaixaBank S.A. National Bank of Slovakia – Bank of America, NA, Frankfurt ICCREA Banca SpA – Istituto
Bank of Poland ABN AMRO Bank N.V. Cassa Centrale Banca – Credito Národná Banka Slovenska Branch Centrale del Credito Coop.
National Bank of Slovakia – Aktia Bank Plc Cooperativo Italiano SpA National Westminster Bank Plc Bank of Greece S.A. ING Bank NV
Národná Banka Slovenska Allied Irish Banks, Plc Cassa Depositi e Prestiti SpA Nordea Bank Abp Bank of Slovenia – Banka Slovenije ING Belgium NV-SA
National Westminster Bank Plc Banca Carige SpA CECABANK S.A. Novo Banco S.A. Bankia S.A. ING LUXEMBOURG S.A.
Nordea Bank Abp Banca d’Italia Central Bank of Savings Banks Oesterreichische Nationalbank Banque de France Intesa Sanpaolo SpA
Novo Banco S.A. Banca Generali SpA Finland Plc OP Corporate Bank Plc. Banque de Luxembourg J.P. Morgan AG
Oesterreichische Nationalbank Banca Monte dei Paschi di Citibank Europe Plc Rabobank Nederland Utrecht Banque Eni S.A. KBC Bank N.V.
OP Corporate Bank Plc. Siena SpA Commerzbank AG Raiffeisen Bank International AG Banque et Caisse d’Epargne La Banque Postale
OTP Bank Plc. Banca Popolare di Sondrio SCPA Crédit Agricole S.A. Raiffeisen Landesbank Südtirol AG de l’Etat Landesbank Baden-Württemberg
Rabobank Nederland Utrecht Banco Bilbao Vizcaya Argentaria Crédit Agricole Italia SpA Santander Consumer Bank AG Banque Internationale Landesbank Hessen-Thueringen
Raiffeisen Bank International AG S.A. Crédit Mutuel – CIC Banques S-Bank Ltd. à Luxembourg S.A. (HELABA)
Raiffeisen Landesbank Südtirol AG Banco BPI S.A. Crédit Mutuel Arkéa SECB Swiss Euro Clearing Bank Barclays Bank Ireland Plc Lloyds Bank Plc
RCB Bank Ltd Banco BPM SpA Credit Suisse (Schweiz) AG GmbH Barclays Bank Plc MUFG Bank, Ltd, Paris Branch
S-Bank Ltd Banco Comercial Português SA Credito Emiliano SpA Skandinaviska Enskilda Banken AB Barclays Bank UK Plc National Bank of Slovakia –
Santander Consumer Bank AG Banco Cooperativo Danske Bank A/S (publ) Belfius Bank SA/NV Národná Banka Slovenska
SECB Swiss Euro Clearing Bank Banco de Sabadell S.A. DB Privat- und Firmenkundenbank Société Générale BGL BNP Paribas National Westminster Bank Plc
GmbH Banco Popular Español S.A. AG (Postbank) Spar Nord Bank A/S BNP Paribas Fortis SA/NV Nordea Bank Abp
Skandinaviska Enskilda Banken AB Banco Santander S.A. De Nederlandsche Bank N.V. Standard Chartered Bank AG BNP Paribas S.A. Novo Banco S.A.
(publ) Banco Santander Totta S.A. DEPObank – Banca Depositaria Svenska Handelsbanken AB BPCE Oesterreichische Nationalbank
Skandinaviska Enskilda Banken Bank of America, NA, Frankfurt Italiana SpA UBS Europe SE BPER Banca SpA Rabobank Nederland Utrecht
S.A., Luxembourg Branch Deutsche Bank AG UniCredit Bank AG bpost SA de droit public Raiffeisen Bank International AG
Société Générale Bank of Greece S.A. Deutsche Bundesbank (HypoVereinsbank) BRED Banque Populaire Raiffeisen Landesbank Südtirol AG
Société Générale Bank and Bank of Ireland DZ BANK AG UniCredit Bank Austria AG Bunq B.V. Santander Consumer Bank AG
Trust S.A. Bank of Slovenia – Banka Slovenije Elavon Financial Services Limited UniCredit SpA Caixa Central de Crédito Agrícola SECB Swiss Euro Clearing Bank
Spar Nord Bank AS Bankia S.A. ERSTE Group Bank AG Unione di Banche Italiane SpA Mútuo GmbH
Sparekassen Kronjylland Banque de France HSBC Bank Plc Caixa Geral de Depósitos S.A. Skandinaviska Enskilda Banken AB
Sparkasse Bank Malta Plc Banque de Luxembourg HSBC France CaixaBank S.A. (publ)
Standard Chartered Bank AG Banque Eni S.A. HSBC UK Bank Plc STEP2 SDD B2B Cassa Centrale Banca – Credito Société Générale
Svenska Handelsbanken AB Banque et Caisse d’Epargne ICCREA Banca SpA- Istituto Cooperativo Italiano SpA Spar Nord Bank A/S
Swedbank AB (publ) de l’Etat Centrale del Credito Coop. ABN AMRO Bank N.V. Cassa Depositi e Prestiti SpA Svenska Handelsbanken AB
Sydbank A/S Banque Internationale à ING Bank NV Banca 5 SpA CECABANK S.A. UBS Europe SE
The Royal Bank of Scottland Plc Luxembourg S.A. ING Belgium NV-SA Banca Carige SpA Citibank Europe Plc UniCredit Bank AG
UBS AG Barclays Bank Ireland Plc ING LUXEMBOURG S.A. Banca d’Italia Commerzbank AG (HypoVereinsbank)
UBS Europe SE Barclays Bank Plc Intesa Sanpaolo SpA Banca Generali SpA Crédit Agricole S.A. UniCredit Bank Austria AG
UBS Switzerland AG Barclays Bank UK Plc J.P. Morgan AG Banca Monte dei Paschi di Crédit Agricole Italia SpA UniCredit SpA
UniCredit Bank AG Belfius Bank SA/NV KBC Bank N.V. Siena SpA Crédit Mutuel – CIC Banques Unione di Banche Italiane SpA
(HypoVereinsbank) BGL BNP Paribas Klarna Bank AB (publ) Banca Popolare di Sondrio SCPA Crédit Mutuel Arkéa
UniCredit Bank Austria AG BNP Paribas Fortis SA/NV La Banque Postale Banco Bilbao Vizcaya Argentaria Credit Suisse (Schweiz) AG
UniCredit SpA BNP Paribas S.A. Landesbank Baden-Württemberg S.A. Credito Emiliano SpA
Bonum Bank Plc Landesbank Hessen-Thüringen Banco BPI S.A. Danske Bank A/S
EBA CLEARING Annual Report 2018
99 104 Appendices
STEP2 CC RT1 ERSTE Group Bank AG The annual accounts for 2018
FinecoBank Spa (and for 2017)
Citibank Europe Plc ABN AMRO Bank N.V. Hanseatic Bank GmbH & Co KG are attached separately.
Commerzbank AG AS LHV Pank Intesa Sanpaolo S.P.A.
DB Privat- und Firmenkunden- AS SEB Pank J.P. Morgan AG
bank AG (Postbank) BANCO BPM S.p.A. Landesbank Baden-Wuerttemberg
Deutsche Bank AG Banca Patrimoni Sella & C. S.p.A. Landesbank Hessen-Thueringen
Landesbank Hessen-Thüringen Banca Popolare di Sondrio Latvijas Banka
(HELABA) Banca Sella Holding S.p.A. Lietuvos bankas
Santander Consumer Bank AG Banca Sella S.p.A. Nordea Bank Abp
UniCredit Bank AG Banco Bilbao Vizcaya Argentaria OP Corporate Bank Plc
(HypoVereinsbank) S.A. Raiffeisenbank International AG
Banco Sabadell S.A. Raiffeisenlandesbank Ober
Banco Santander S.A. oesterreich AG
Bankia S.A. Santander Consumer Bank AG
Banca Nazionale del Lavoro S.p.A. Svenska Handelsbanken AB (publ)
Bonum Bank Plc Swedbank AB
BRED Banque Populaire Swedbank AS
Bunq B.V. TeamBank AG
Caixabank S.A. UniCredit Bank AG
Central Bank of Savings Banks (HypoVereinsbank)
Finland Plc UniCredit S.p.A.
Commerzbank AG
Coop Pank aktsiaselts
Credit Agricole Cariparma S.p.A.
Crédit Mutuel Arkéa
Danske Bank A/S, Finland Branch
DEPObank – Banca Depositaria
Italiana SpA
Deutsche Bank AG
DZ BANK AG
EBA CLEARING Annual Report 2018
IMPRINT Photographs
Mirène Schmitz, Bonn
© 2019 EBA CLEARING Norbert Miguletz, Frankfurt am Main
All rights reserved Johannes Haas Fotografie, Rösrath
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