In cross-border payments, especially between the EU and the UK, the payer's address should be included as per regulatory requirements. This requirement is part of the EU Wire Transfer Regulations and is outlined in guidance from the European Payments Council and the FCA. However, there can be issues where the payer's address is missing in payment messages, which can impact the payment process.
Why is the payer's address missing?
The payer's address may be missing from the payment messages for several reasons:
1. Regulatory Requirements: The payer's bank (payer PSP) is responsible for including the payer's address in the payment message. Token.io only initiates the payment but does not handle the transmission of the payer's address to the payee bank.
2. Discretionary Acceptance: Receiving banks (payee PSPs) have some discretion in accepting payments with missing information. According to Article 8 of the Fund Transfer Regulations, occasional missing data is permissible, but consistent absence of payer data is not acceptable.
3. Payer Bank Responsibilities: The payer’s bank should already have the payer’s address and be responsible for including it in the payment message. However, issues can arise if the payer bank does not comply with these requirements.
What can be done?
Unfortunately, there is limited action Token.io can take directly regarding the payer's address once the payment initiation has occurred. Here’s what you can consider:
1. Ensure Accurate Payment Initiation: Confirm that all required data, including the payer’s address, is correctly provided in the payment initiation call. However, note that including the payer’s address in the initiation call does not guarantee it will be included in the final payment message by the payer bank.
2. Contact Payer Bank: If the payer’s address is consistently missing, it may be beneficial to contact the payer's bank directly to ensure they are including the necessary information in their payment messages.
3. Review Receiving Bank Policies: Understand the policies of the receiving bank (payee PSP) regarding the acceptance of payments with missing information. This can help address issues if the receiving bank has specific requirements or discretion in handling incomplete data.
For more detailed information, you can review the relevant regulations and guidance, including the EU Wire Transfer Regulations and the FCA’s cross-border payment requirements. If you have further concerns or require assistance, please reach out to our support team.