Verification of Payee LEI Checks in Ireland

Verification of Payee LEI checks in Ireland offer a possible alternative to the usual IBAN name check, but companies do not need an LEI to receive payments. For a legal-person payee, the check can compare its IBAN with its LEI only when the payer’s payment service provider (PSP) offers that channel and the payee’s PSP holds the LEI. Verification gives the payer a result before authorisation of a euro credit transfer.

What this means in Ireland

Ireland is in the euro area. Under Regulation (EU) 2024/886 of 13 March 2024 (the Instant Payments Regulation), which amended Regulation (EU) No 260/2012, Article 5c(9) required PSPs in euro-area Member States to comply with the Verification of Payee (VoP) requirements by 9 October 2025. That date has passed; it is a PSP compliance date, not a deadline for Irish companies to obtain an LEI. The text of Regulation (EU) 2024/886 on EUR-Lex sets out the requirement.

The Central Bank of Ireland says that, from 9 October 2025, all banks and relevant PSPs in Ireland and the euro area must facilitate sending SEPA instant credit transfers in euro. It also identifies 9 October 2025 as the date VoP took effect. VoP covers standard as well as instant euro credit transfers; the two requirements should not be confused.

A Galway limited company invoicing EU customers in euro can check the payee name and IBAN it supplies to those customers. If it wants customers to use an LEI instead of its name for verification, it should first ask about the conditions at both PSPs; the Irish compliance date does not establish that either PSP supports an LEI check. For a Dublin group paying suppliers in bulk files, the relevant question is how its payment process handles verification results and any choice to opt out for packaged orders. Neither example changes the underlying rule: an LEI check is conditional, not mandatory.

Key points for an Irish business

• The standard VoP service checks the payee name against the IBAN supplied by the payer.
• For a legal person, an alternative check may use an LEI, fiscal number or European unique identifier (EUID), subject to Article 5c’s conditions.
• VoP applies to standard and instant credit transfers denominated in euro within the EU.
• A mismatch gives the payer information to consider; it does not block authorisation.
• Do not treat an LEI printed on an invoice as proof that a PSP has recorded it.

The European Central Bank’s Instant Payments Regulation overview confirms the scope of euro credit transfers and the application of verification to both standard and instant transfers.

When can an LEI replace the payee name check?

Article 5c(1) requires the payer’s PSP to offer verification immediately after the payer provides the payee details and before authorisation, regardless of how the payment is initiated. Ordinarily, the payee’s PSP checks on request whether the IBAN and payee name match. If they do not, the payer is notified that authorising the transfer may send funds to an account not held by the indicated payee. The ECB describes the results shown to payers as “match”, “close match”, “no match” and “other”.

Article 5c(1)(b) permits a different comparison for a payee that is a legal person. The payer’s PSP must offer a channel for supplying the IBAN with another data element that unambiguously identifies the payee, and that same element must be available in the payee’s PSP’s internal system. The payee’s PSP then checks, on request, whether the IBAN and identifier match. Examples in the regulation are a fiscal number, an EUID and a Legal Entity Identifier (LEI), a unique alphanumeric reference code based on ISO 17442 and assigned to a legal entity.

These conditions explain why putting an LEI on an invoice does not automatically enable an LEI-based VoP check. Under Article 5b(2), PSPs must provide the Article 5c verification service to payment service users free of charge. Article 5c(5) also says that verification must not prevent the payer from authorising the transfer.

How the EPC identification-code check works

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 checking an identification code instead of a legal person’s name when the requesting PSP offers that channel and the responding PSP has the code. Its examples include an LEI, a VAT number and a fiscal number. The requesting PSP can use the EPC Directory Service to check whether the responding PSP supports the identification-code route; that does not establish support for LEI checks at every PSP.

For a check against an IBAN and identification code, 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 state that the LEI field follows ISO 17442. A general VoP result does not, by itself, show that an LEI was checked. Ask which details were submitted if a result is unexpected.

Bulk files, authorisation and liability

Under Article 5c(6), a PSP must let a payment service user that is not a consumer opt out of verification when submitting multiple payment orders as a package. The user must also be able to opt back in at any time. A business paying suppliers through bulk files can therefore decide how that choice fits its review process rather than assume it must opt out.

VoP supplies information before authorisation; staff should investigate a mismatch rather than expect the PSP to stop the transfer. Article 5c(8) sets out 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. Ask your PSP or adviser to assess a particular dispute.

VoP dates and the next checks to make

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

These are statutory PSP deadlines under Article 5c(9), separate from the EPC rulebook’s effective date. For your company’s next payment-process review:

• Check the legal-person name and IBAN provided to customers and held in supplier records.
• Ask the payer’s PSP whether it offers an identification-code channel, and ask the PSP holding your account whether your LEI is in its internal system.
• Decide who reviews a mismatch or a “matching not possible” result before a transfer is authorised.
• If you already use an LEI, check its details and renew an LEI when needed. If you want an identifier for a possible LEI check and do not have one, you can apply for an LEI; obtaining one does not establish that either PSP offers the check.

For related developments, follow the LEIFast regulation updates. The immediate question for your PSP is which verification channel it offers and which payee identifiers it holds.