South Africa | March 2019
Dear Realpay User
The end of the first quarter 2019 is already in sight. Not only is business activity in industry on the increase, it is also marked this year by significant change at legislative and policy level. A key initiative is the National Treasury and SARB’s review process of the National Payments System Act, which is gaining momentum. The SARB published a policy document and together with National Treasury consulted with industry during February for comment by end February, a process to which Real Pay contributed through is industry association.
Apart from legislative change, DebiCheck remains high on the radar. Industry is gearing up to meet the timelines as contained in the amended Directive of the SARB issued during December 2018. To this end, we remind our Users of the Real Pay DebiCheck update sent on 14 December 2018. This newsflash highlighted key aspects and dates contained in the amended Directive and as published in the Government Gazette on 14 December 2018, No. 42100.
Functionality and stability factors relating to non-face-to-face authentication and payer contactability have potential to influence the markets. Therefore, the SARB commissioned PASA and the non-banks to prepare an AC implementation plan with clearly defined phases and timelines to monitor the implementation plan and the participants’ progress therein.
Real Pay remains actively involved in the PASA project via our technical associations, CIBA and the EDO PSSF.
We remind our Users of the important dates in the run-up and after the implementation date of 31 October 2019:
- Current – 31 October 2019:
- AC, NAEDO and AEDO to process simultaneously in the early morning processing window;
- 1 November 2019 – 31 October 2020:
- Proceed to process AEDO and NAEDO instructions in the early window, subject to AC debit orders and AEDO instructions being given priority over NAEDO instructions;
- 1 May 2020 – 31 October 2020:
- No origination of new NAEDO and AEDO instructions; and
- 31 October 2020 (Sunset date):
- End date of processing any NAEDO and AEDO instructions.
Industry finalised an implementation plan distinguishing separate phases and identifying specific objectives to be achieved per phase. This plan will be presented to the SARB for approval. Key phases distinguished in the plan are the run-up to the implementation date of 31 October 2019 and the phase towards the sunset date of 31 October 2020.
Core aspects currently attracting industry focus revolve around system stability and functionality, particularly non-face-to-face and remote face-to-face authorisation. Real Pay participates in the industry structures with weekly submissions to the EDO PSSF and its sponsor banks, Absa and FNB, on issues experienced. In addition, Real Pay participates in the EDO PSSF committee established to pursue further alternatives to the authentication and authorisation challenges in the non-face-to-face markets.
Our focus remains on increasing User volumes in the Controlled Pilot and Controlled Live environments.
Onboarding is progressing well, with increased User participation. Technical discussions with our integrated partners are concluded on a weekly basis. We remind Users who have not yet completed their onboarding documentation to do so in order to participate in the live testing and pilot environments.
Contact Real Pay at email@example.com to ensure that you are DebiCheck ready.
Regulatory Compliance and Quality Assurance
Real Pay would like to thank our Users for their ongoing cooperation in maintaining compliant participation and supporting a safe and efficient National Payments System. To this end, it is imperative that every transaction is matched to a correct, compliant and valid authority to debit (mandate) and company agreement or contract.
Debit order abuse remains a key focus area in the payments industry. Therefore, it is imperative that the critical elements (Abbreviated name, Beneficiary User name, Deduction date, Deduction amount, Surname, Initial, and Bank account number of account holder) are incorporated in all debit order arrangements. These critical elements are being monitored by PASA and the banks.
As an outcome of Real Pay’s internal quality assurance assessments with Users, the Abbreviated name presents challenges from time-to-time in instances where the underlying agreements have been ceded to a third party and the beneficiary User subsequently changes. Users are reminded to include the amended Abbreviated name. The Abbreviated name is a powerful mechanism for the consumer and/or debtor to recognise the originator of the debit order and can also circumvent disputes.
We remind Users that the EDO PSSF annual invoices have been circulated viathe PSSF and are payable by 28 February 2019. If you have not received your EDO PSSF invoice yet, contact us on firstname.lastname@example.org 012 347 0729 for assistance.
Payments Governance and Regulation – NPS Act 78 of 1998
National Treasury and the SARB recently published a policy paper titled “Review of the National Payment System Act 78 of 1998” that has been circulated for comment due 28 February 2019. Real Pay is providing input through its association, CIBA. A number of developments prompted a rethink of the relevance of the existing payments regulatory framework. These include global policy developments relating to financial inclusion, financial stability, effectiveness, integrity, and international standards and standard setting bodies such as the Committee on Payments and Market Infrastructures. The payments industry is moving towards a digital age and is becoming increasingly innovative along with advanced financial technology; therefore, the legislative framework needs to be flexible and adaptable to these changes.
Real Pay supports the enhancement of a robust and effective NPS regulatory framework and appropriate regulation that is fit for purpose and aligned with best international standards and practices.
Real Pay Team