The instant payments regulation: A technical roadmap for EMIs to achieve real-time settlement

A new foundation is set for European payments in 2026, and those who are prepared will make it, but those who are still laying bricks will likely struggle. This is not a market cycle or investment pressure—this is a regulatory requirement with a real enforcement mechanism.

By April 2026, every payment service provider in the eurozone must submit their first harmonised report under the EU’s Instant Payments Regulation (IPR). By January 2027, EMIs must be able to receive instant euro payments. And by July 2027, we must be able to send them.

And here’s the unpleasant truth: one in five EMIs are predicted to miss the July 2027 deadline. The reason is not a lack of ambition, but an underestimation of the infrastructure needed for real-time processing.

I have seen the consequences for institutions that view compliance as a checkbox rather than an architectural requirement. The IPR is not a checkbox. It is a large-scale restructuring delivered through regulation.

The landscape: Why 2026 is the inflexion point

The regulation requires that instant transfers in euros be completed within ten seconds, 24/7/365. Fees cannot exceed those for non-instant transfers. Verification of Payee (VoP) must be provided free of charge. Sanctions checks must occur in real time.

For EMIs accustomed to batch processing and overnight settlement, this is existential. By 9 April 2026, all PSPs must submit their first annual reports to national authorities, covering charges, volumes, and rejected payments due to sanctions. The European Banking Authority has published binding Implementing Technical Standards. There is no flexibility—only pass or fail.

By 9 January 2027, EMIs in eurozone countries must receive instant payments. By 9 April 2027, we must send them.

The technical challenge no one wants to admit

Sanctions screening in ten seconds. Under IPR, every instant payment must be screened against updated sanctions lists within the ten-second window. That means moving from batch to real-time verification—integrated into the payment flow itself.

Verification of Payee is standard. From 9 October 2025, eurozone PSPs must offer free VoP for all transfers. This mandatory real-time check requires integration with the EPC’s VoP scheme without adding delay.

Daily sanctions list updates. The IPR requires updates at least daily, or immediately after list changes. For EMIs with rigid infrastructure, this is a fundamental redesign. 

24/7/365 availability. Instant payments do not stop. Infrastructure must always meet the ten-second SLA.

The strategic opportunity hidden in compliance

I believe IPR is a huge opportunity for EMIs who get it right. When the rules are fully implemented, all PSPs will offer the same basic service. Competition will shift to reliability, value-added services, and turning compliance into trust.

Direct SEPA access is now on the table. Changes to the Settlement Finality Directive allow EMIs to become direct SEPA participants. Four in ten EMIs are planning to take advantage.

Data becomes a competitive asset. The EBA’s reporting requirements force granular data collection. EMIs that use this data for analytics will make smarter decisions.

Trust is the ultimate differentiator. VoP improves customer experience, and EMIs that deliver reliable instant settlement will earn loyalty no discount can match.

A technical roadmap for EMI leaders

1. Audit for real-time readiness. If you cannot answer whether your systems meet ten-second SLAs during peak loads, you are not ready.
2. Redesign sanctions screening around the customer. As KPMG notes, the only way to screen instant payments in ten seconds is to pre-screen customers.
3. Build VoP integration now. The EPC rulebook is published. Integrate early to optimise speed.
4. Prepare for the April 2026 reporting deadline. The XBRL templates and data requirements are finalised. Start capturing data now.
5. Evaluate direct SEPA access. Research shows that most EMIs would switch providers if the SEPA Instant service is unreliable.

The bottom line

The Instant Payments Regulation is the biggest shift in European payments since SEPA. It is not a compliance task to delegate—it is a fundamental overhaul of how EMIs operate.

The firms that survive will treat IPR as a strategic inflexion point. They will invest in infrastructure, redesign compliance for real-time, and use regulation to build trust.

For my fellow EMI founders: time is running out. April 2026 is almost here.