Verification of Payee LEI Checks in Estonia

Verification of Payee LEI checks in Estonia offer a conditional alternative to checking a payee’s IBAN against its name. Companies do not need an LEI for the usual check: an LEI can be checked only for a legal-person payee when the payer’s payment service provider (PSP) offers an identifier-check channel and the payee’s PSP holds that identifier. Verification covers standard and instant credit transfers in euro and gives the payer a result before authorisation.

What this means in Estonia

Estonia is in the euro area, so its PSPs have had to offer Verification of Payee for standard and instant euro credit transfers since 9 October 2025. The compliance date comes from Regulation (EU) 2024/886 of 13 March 2024, the Instant Payments Regulation, Article 5c(9). It is a deadline for PSPs, not a date by which companies had to obtain an LEI.

The European Commission Representation in Estonia said that, from 9 October 2025, PSPs must offer the payee verification service for euro credit transfers free to the payer. In Estonia, the service is also described as makse saaja kontroll. The announcement covers payee verification; it does not establish that every PSP offers checks against an LEI.

Consider Tartu OÜ receiving invoices from foreign partners. When it prepares a euro credit transfer, the relevant check takes place before it authorises payment. A Tallinn online shop paying suppliers by payment file has a different operational question: who reviews the verification results for its packaged orders? These examples do not change the underlying rule. The company’s practical starting point is to confirm which payee details it uses and ask its PSP whether it offers identifier-based checks. An LEI printed on an invoice alone does not establish that the PSP holding the payee’s account has recorded it.

Key points for company payments

• The usual check compares the payee’s IBAN with the name supplied by the payer.
• For a legal-person payee, a qualifying identifier can be checked instead of the name if the conditions for that channel are met.
• A mismatch warns the payer but does not block authorisation.
• Estonian PSPs have had to comply since 9 October 2025; the later date for PSPs in non-euro EU Member States is 9 July 2027.

The European Central Bank’s Instant Payments Regulation overview confirms that verification applies to both standard and instant credit transfers denominated in euro within the EU. Its descriptions of payer-facing results include “match”, “close match”, “no match” and “other”.

When Article 5c permits an LEI check

Regulation (EU) 2024/886 amended Regulation (EU) No 260/2012. Article 5c(1) requires the payer’s PSP to offer verification immediately after the payer provides payee details and before the payer can authorise the transfer, regardless of the initiation channel. Under the usual check, the payee’s PSP verifies on request whether the IBAN and name match. If they do not, the payer receives a warning that authorising the transfer may send funds to an account not held by the indicated payee.

Article 5c(1)(b) provides an alternative for a legal-person payee. If the payer’s PSP offers a channel to submit an IBAN with another data element that unambiguously identifies the payee, and the payee’s PSP has the same element in its internal system, the payee’s PSP checks whether they match. The regulation lists a fiscal number, European unique identifier (EUID) and Legal Entity Identifier (LEI) as examples. It defines an LEI as a unique alphanumeric reference code based on ISO 17442 and assigned to a legal entity.

Those conditions make an LEI useful only where the relevant PSPs can handle the check. Displaying one in payment documents does not create an identifier-check channel. Article 5b(2) requires verification services under Article 5c to be free of charge to payment service users; Article 5c(5) says verification must not prevent the payer from authorising a transfer.

How PSPs report an identifier-check result

The European Payments Council (EPC) Verification of Payee Scheme Rulebook v1.1 was issued on 16 March 2026 and has been effective since 20 September 2026. It describes an identification-code check for legal-person payees as an alternative to a name check when the requesting PSP offers that channel and the responding PSP has the code. Its examples include an LEI, VAT number and fiscal number.

The requesting PSP can consult the EPC Directory Service to see whether the responding PSP supports an identification-code check. Support for the route should not be assumed for every PSP. For an identification-code and IBAN check, the EPC VOP API Specifications v1.1.1 set out these responding-PSP codes:

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

The specifications say the LEI field follows ISO 17442. These codes concern an identification-code check; a general verification result does not, by itself, show that an LEI was checked. If a result is unexpected, establish which details were submitted and whether both PSPs could use the identifier.

Bulk payments, authorisation and liability

Under Article 5c(6), PSPs must allow payment service users that are not consumers to opt out of verification when submitting multiple payment orders as a package. Those users must be able to opt back in at any time. A business using payment files should decide who can make that choice and who will review results before authorisation; the rule does not require it to opt out.

A no-match result is a warning, not a payment block. Article 5c(8) also sets out 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 causes a defectively executed transaction, it must refund the payer without delay. For a disputed transfer, check the particular facts with your PSP or adviser.

Verification of Payee compliance dates

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

These are PSP compliance dates under Article 5c(9). The EPC rulebook’s effective date of 20 September 2026 is separate from those statutory dates.

What to check with your PSP

• Review payee records: confirm the name and IBAN used for supplier payments and supplied to customers.
• Ask about both sides of an LEI check: find out whether the payer’s PSP offers an identifier-check channel and whether the PSP holding the payee’s account has recorded its LEI.
• Share accurate details: if your company has an LEI, provide it to your PSP and include it on invoices or supplier forms where useful.
• Maintain the identifier you use: check its recorded details and renew an LEI when needed.
• Set a response process: decide how staff will handle a mismatch or a result stating that matching is not possible before authorisation.

If your company does not have an LEI and wants to make one available for eligible checks, it can apply for an LEI; the conditions at both PSPs still determine whether a check is possible. For related developments, see LEIFast’s Estonia regulation updates. First, ask your PSP which verification channels it offers and which identifiers it holds.