4.3. Transmitting and receiving information with the transfer in ac-cordance with Articles 4 to 8, 10 to 12, 14 to 17 and 19 to 21 of Regulation (EU) 2023/1113

PSPs, IPSPs, CASPs and ICASPs should use infrastructures and services for the transmission and reception of information that are technically capable of the full transmission and reception of information without gaps or errors in the presentation of the information as specified in these Guidelines.

PSPs, IPSPs, CASPs and ICASPs should ensure that their systems are able to maintain data integrity, in particular where information has to be converted into a different format before transmitting it or after receiving it. PSPs, IPSPs, CASPs and ICASPs that cannot ensure that their systems are able to transmit, receive or convert the information without error or omission should change to a system which is capable of that.

PSPs, IPSPs, CASPs and ICASPs should ensure that the systems they use for the transfer of information are secure. CASPs should also apply the guidance provided to PSPs by the EBA Guidelines on ICT and security risk management⁶ and the EBA Guidelines on outsourcing arrangements⁷ .

Transfer of crypto-assets

⁶ EBA/GL/2019/04.

⁷ EBA/GL/2019/02.

CASPs and ICASPs may, by way of derogation from paragraph 21 and until 31 July 2025, exceptionally use infrastructures or services where technical limitations in relation to the completeness of data need to be compensated by additional technical steps or fixes to fully comply with these Guidelines. Those additional procedures should at least include alternative mechanisms for collecting, holding and making available to the receiving CASP or ICASP in the transfer chain the information that cannot be transmitted due to technical limitations.

When transmitting information in accordance with Article 14 of Regulation (EU) 2023/1113, the originator’s CASP and ICASP should:

• a) transmit the information either as part of, or incorporated into, the transfer on the blockchain or on another distributed ledger technology (DLT) platform, or inde-pendently via different communication channels – including via direct communication between CASPs, application programming interfaces (APIs), code solution running on top of the blockchain and other third-party solutions; and
• b) transmit the required information immediately and securely and no later than the in-itiation of the blockchain transaction.

When choosing the messaging or payment and settlement system(s), CASPs and ICASPs should take proportionate, risk-sensitive measures to assess:

• a) the system ’ s ability to communicate with other internal core systems and with the messaging or payment and settlement systems of the counterparty of a transfer, and its compatibility with other blockchain networks;
• b) the reachability of the protocol (i.e. the diversity and accuracy of counterparties that can be reached using the protocol – subject to the CASP's own due diligence assess-ment – and the rate of transfers that would successfully be sent to the intended ben-eficiary or received from the originator);
• c) how the system enables the CASP or ICASP to detect a transfer with missing or incom-plete information;
• d) data integration capabilities, data security and data reliability of the system.

4.3.2. Multi-intermediation and cross-border transfers

Transfer of funds

PSPs and IPSPs that enable the execution of transfers with two or more IPSPs or PSPs on a cross-border basis should describe in their policies and procedures how the information on the payer and payee is transmitted throughout the transfer chain to the next PSP and IPSP in the transfer chain.

For transfers that have not been batched, the PSP or IPSP should:

• a) consider the transfer chain (from end to end) as one such that the flow of information on the original payer and payee is preserved;
• b) where the transfer is made from a cross-border channel to a domestic channel, select the domestic system that maximises the transparency of the cross-border nature of the transfer and ensures that the information about the parties transmitted to the next PSP in the payment chain can be readily understood by all intermediary and/or beneficiary PSPs;
• c) in cases of doubt, assume that the transfer is a cross-border transfer, resulting in the use of appropriate payment channels that may facilitate the necessary transmission of information.

IPSPs are only responsible for passing through the payment message using the data that they have been provided with by the previous PSP/IPSP in the transfer chain, subject to the specific check required by Articles 10 to 13 of Regulation (EU) 2023/1113.

PSPs and IPSPs should not treat a transfer from the payer to the payee as liquidity movement or settlement on the PSP ’s and IPSP’s own account.

Transfer of funds and crypto-assets

Where the intermediary does not receive the required information related to a transfer, par-ticularly in the case of batch transfers, the IPSP or ICASP should obtain the missing information via an alternative channel mechanism, including methods such as APIs and third-party solu-tions, to comply with the requirements set in Regulation (EU) 2023/1113.