Regarding payments between PSPs

1) Are the credit institutions obliged to request payment service providers to disclose payment details as described in the Regulation (EU) 2015/847 in case of batch file transfers? 2) If yes, to what extent should the obligation to disclose payment information be applied?

Regarding the implementation of Regulation (EU) 2015/847 of the European Parliament and of the Council of 20 May 2015 on information accompanying transfers of funds and repealing Regulation (EC) No 1781/20 (hereinafter – Regulation (EU) 2015/847 there are observed the situations when payment service providers (PSPs)(i.e. electronic money institutions) have collected funds from their customers, bundled and transfer these funds in a batch file for transmission to their accounts in other credit institutions (as well as in EU and outside EU), Respectively the credit institution does not receive information on the payment service providers customers (payer) and payee of funds. Regarding point 2 of the Article 2 of the Regulation (EU) 2015/847 this Regulation shall not apply to the services listed in points (a) to (m) and (o) of Article 3 of Directive 2007/64/EC. Point m) Article 3 of this Directive states that this Directive does not apply to the payment transactions carried out between payment service providers, their agents or branches for their own account. Also point c) paragraph 4 of Article 2 of the Regulation (EU) 2015/847 states that this Regulation shall not apply to transfers of funds where both the payer and the payee are payment service providers acting on their own behalf.