Verification of Payee LEI Checks in Malta

Verification of Payee LEI checks in Malta offer an alternative to checking a payee’s IBAN against its name; they do not require a company to hold an LEI. For a legal-person payee, the payer’s payment service provider (PSP) must offer an identifier-check channel, and the payee’s PSP must hold the same identifier. Verification gives the payer a result before a euro credit transfer is authorised.

What this means in Malta

Malta is in the euro area, so its PSPs have had to offer Verification of Payee (VoP) under Article 5c since 9 October 2025. The requirement covers standard and instant credit transfers in euro. It does not mean that every PSP offers an LEI-based check: the identifier route has its own conditions, including the availability of the LEI in the payee PSP’s internal system. The compliance date is set out in Regulation (EU) 2024/886 on EUR-Lex.

The Central Bank of Malta’s SEPA information states that the Minister for Finance appointed it competent authority for SEPA implementation under Regulation (EU) No 260/2012. It also describes the Instant Payments Regulation’s requirement for PSPs to verify whether a beneficiary’s IBAN matches their name. The Bank gives 9 January 2025 as the deadline for eurozone PSPs to receive instant payments and 9 October 2025 as the deadline to send them. Those receiving and sending dates concern instant payments; the Article 5c VoP compliance date for euro-area PSPs is 9 October 2025.

Consider a Gozo hospitality company receiving euro deposits from foreign tour operators. It can give payers its correct IBAN and payee name, then ask the PSP holding its account whether its LEI is recorded there if it wants payers to use an identifier check. A Valletta SME that pays suppliers in bulk can instead review how its staff respond to a reported mismatch and whether it wishes to use the opt-out available for packaged payment orders. Neither example establishes what a particular PSP offers; the company must check its arrangements with its PSP.

Key points for company payment teams

• The usual VoP check compares the payee’s IBAN with the name supplied by the payer.
• For a legal person, a qualifying identifier such as an LEI may be checked instead when the conditions in Article 5c(1)(b) are met.
• VoP covers standard and instant credit transfers denominated in euro within the EU.
• A mismatch is information for the payer, not a block on authorisation.
• VoP verification services must be free of charge to payment service users.

The European Central Bank’s Instant Payments Regulation overview confirms that verification applies to both standard and instant euro credit transfers. It describes the results presented to payers as “match”, “close match”, “no match” and “other”.

When can VoP check an LEI instead of a name?

Regulation (EU) 2024/886 of 13 March 2024, the Instant Payments Regulation, amended Regulation (EU) No 260/2012. Article 5c(1) requires the payer’s PSP to offer verification immediately after the payer provides the payee details and before the payer can authorise the transfer, regardless of how the payment is initiated.

Under Article 5c(1)(a), 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 the funds to an account not held by the indicated payee. This is the name check a company should expect when it supplies a payee name and IBAN.

Article 5c(1)(b) sets out a different comparison for a legal-person payee. If the payer’s PSP offers a channel for submitting the IBAN with another element that unambiguously identifies the payee, and the payee’s PSP has that element in its internal system, the payee’s PSP checks whether the IBAN and element match. The regulation names a fiscal number, European unique identifier (EUID) and Legal Entity Identifier (LEI) as examples. An LEI is a unique alphanumeric reference code based on ISO 17442 and assigned to a legal entity.

Putting an LEI on an invoice cannot, by itself, make this check available. Ask whether the payer’s PSP accepts an identification code through its payment channel and whether the PSP holding the payee’s account has recorded that code. Article 5b(2) requires VoP verification services to be provided free of charge, while Article 5c(5) says verification must not prevent the payer from authorising a transfer.

How the EPC identification-code check works

The European Payments Council VOP Scheme Rulebook v1.1, issued on 16 March 2026 and effective since 20 September 2026, describes a code check as an alternative to a legal person’s name check. The requesting PSP must offer the channel, and the relevant code must be available in the responding PSP’s system. The rulebook gives LEIs, VAT numbers and fiscal numbers as examples.

A requesting PSP can consult the EPC Directory Service to determine whether the responding PSP supports identification-code checks. That does not establish that every PSP supports an LEI check. Companies should confirm the available channel and the identifier held for their account rather than infer either from a general VoP result.

For an identification-code and IBAN comparison, the EPC VOP API Specifications v1.1.1 specify these responding-PSP codes:

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

The specifications state that the LEI field follows ISO 17442. These codes describe an identification-code check; a payer seeing a general VoP result should not assume an LEI was used.

Bulk payments, results and PSP liability

Under Article 5c(6), a PSP must let a payment service user that is not a consumer opt out of verification when it submits multiple payment orders as a package. The user must be able to opt back in at any time. For a company paying suppliers in bulk, the choice belongs in its payment review process; the provision does not require it to opt out.

Staff should investigate an unexpected mismatch or a result stating that matching is not possible before deciding whether to authorise. Article 5c(8) also sets defined liability rules: a PSP that has fulfilled Article 5c is not liable for a transfer to an unintended payee based on 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. Check the facts of a disputed transaction with the PSP or an adviser.

Compliance dates and next steps

PSP location	Article 5c compliance date	Status on 18 October 2026
Euro-area Member States, including Malta	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), not deadlines for companies to obtain an LEI. The EPC rulebook’s effective date is separate from them.

• Check payment records: confirm the IBAN and legal-person name shared with payers and recorded for suppliers.
• Ask about both sides of the check: find out whether the payer’s PSP offers an identification-code channel and whether the PSP holding your account has your LEI in its system.
• Keep details current: if you use an LEI, check its details and renew your LEI when needed.
• Set a review procedure: decide who investigates mismatches and results stating that matching is not possible, including for bulk payment files.

If your company wants to share an LEI for possible identifier checks but does not have one, it can apply for an LEI. The first operational step is to ask your PSP which checks it offers and which identifiers it holds. For related developments, see the LEIFast regulation updates.