Verification of Payee LEI Checks in the EU

Verification of Payee LEI checks are an alternative to the usual IBAN and payee-name check, not a requirement for companies to hold an LEI. For a payee that is a legal person, an IBAN can be checked against its LEI only if the payer’s payment service provider (PSP) offers that channel and the payee’s PSP holds the same identifier. The service applies to euro credit transfers and gives the payer a result before authorisation.

Key points for companies

• The usual Verification of Payee (VoP) check compares the payee’s IBAN with the name entered by the payer.
• An identifier check can use an LEI, a fiscal number or another qualifying identifier for a legal person, subject to the conditions in Article 5c.
• VoP applies to both standard and instant credit transfers denominated in euro within the EU.
• A mismatch warns the payer; verification does not prevent the payer from authorising the transfer.
• Euro-area PSPs have had to comply since 9 October 2025. PSPs in Member States whose currency is not the euro will have to comply by 9 July 2027.

The European Central Bank’s Instant Payments Regulation overview explains the scope of euro credit transfers and confirms that verification covers standard as well as instant transfers.

What Article 5c requires before a transfer

Regulation (EU) 2024/886 of 13 March 2024, the Instant Payments Regulation, amended Regulation (EU) No 260/2012. Under Article 5c(1), the payer’s PSP must offer verification immediately after the payer supplies the payee details and before the payer can authorise a credit transfer, regardless of the initiation channel. The text of Regulation (EU) 2024/886 on EUR-Lex sets out both the name and identifier checks.

For the usual IBAN name check company payers encounter, the payee’s PSP verifies, on request, whether the IBAN and payee name match. If they do not, the payer is notified that authorising the transfer may send the money to an account not held by the indicated payee. The ECB describes the results presented to payers as “match”, “close match”, “no match” or “other”.

Article 5c(1)(b) also provides for a different comparison when the payee is a legal person. If the payer’s PSP offers a channel for submitting the IBAN with another data element that unambiguously identifies the payee, and the payee’s PSP has that same element in its internal system, the payee’s PSP verifies whether the IBAN and identifier match. The regulation gives a fiscal number, a European unique identifier (EUID) and an LEI as examples. An LEI is a unique alphanumeric reference code based on ISO 17442 and assigned to a legal entity.

These conditions matter. Supplying an LEI on an invoice does not by itself mean the payer can select an LEI check or that the payee’s PSP can perform one. The payer’s PSP must offer the channel, and the payee’s PSP must hold the identifier. Verification services under Article 5c must be provided to payment service users free of charge, and verification must not prevent the payer from authorising the transfer.

How an LEI check works in the EPC VOP scheme

The European Payments Council (EPC) VOP Scheme Rulebook v1.1 was issued on 16 March 2026 and has been effective since 20 September 2026. It describes the identification-code check as an alternative to checking a legal person’s name where the requesting PSP offers the channel and the code is available in the responding PSP’s system. Its examples include an LEI, a VAT number and a fiscal number.

The requesting PSP can check the EPC Directory Service to see whether the responding PSP supports an identification-code check. That is a way to establish whether the route is available; it does not mean every PSP supports LEI-based checks. A company that wants to use its LEI in payment details should ask its PSP what it can accept and ask the PSP holding its account whether the LEI is recorded in its internal system.

For an identification-code and IBAN check, the EPC VOP API Specifications v1.1.1 provide three responding-PSP codes:

• MTCH: match.
• NMTC: no match.
• NOAP: matching not possible.

The API specifications state that the LEI field follows ISO 17442. These are codes for the identification-code check, not a reason to assume an LEI was checked whenever a payer sees a general VoP result. If a result is unexpected, the practical question is which details were submitted and whether the relevant PSPs support and hold the identifier.

Bulk payments: opting out and liability

Article 5c(6) requires PSPs to give payment service users that are not consumers a way to opt out of verification when submitting multiple payment orders as a package. Those users must also be able to opt back in at any time. This is a choice concerning verification for packaged orders, not a rule requiring companies to opt out.

Before changing a bulk-payment process, establish who makes that choice within the organisation and how payment details are reviewed. VoP provides information before authorisation; it does not prevent authorisation. A business should therefore treat a mismatch as information to investigate rather than assume that the PSP will stop the transfer.

Article 5c(8) addresses PSP liability in defined circumstances. A PSP that has fulfilled Article 5c is not liable for executing a transfer to an unintended payee on the basis of an incorrect unique identifier. If the payer’s PSP fails to comply with Article 5c(1) and that failure results in a defectively executed transaction, it must refund the payer without delay. Liability in a particular case depends on the facts; check a disputed transaction with your PSP or adviser.

VoP compliance dates

PSP location	Article 5c compliance date	Status on 18 October 2026
Euro-area Member States	9 October 2025	Applicable
EU Member States whose currency is not the euro	9 July 2027	Will apply

These are deadlines for PSPs under Article 5c(9). The EPC rulebook’s effective date is separate from those statutory compliance dates.

What companies should do

• Confirm the payment details: check the legal-person name and IBAN supplied to customers and used in supplier records.
• Ask both PSPs about identifier checks: establish whether the payer’s PSP offers an identification-code channel and whether the PSP holding your account has recorded your LEI. Do not assume that an LEI displayed on a document is held by the PSP.
• Make the identifier available: if your company has an LEI, provide it to your PSP and include it on invoices or supplier forms where useful for sharing accurate details.
• Maintain an existing LEI: if you use one, check its details and renew an LEI when needed. Keeping the LEI active means the identifier your PSP and payers see stays current.
• Set a response process: decide how staff will review a reported mismatch or a result stating that matching is not possible before authorising a payment.

A company that wants payers to be able to use an identifier check and does not yet have an LEI can apply for an LEI. The immediate step is to ask the PSP which verification channels it offers and which identifiers it holds; for related changes, follow the LEIFast regulation updates.