Confirmation of Funds (CoF) request by a PISP in case of batch processing system

Article 36(1)(c) of the Commission Delegated Regulation (EU) 2018/389  requires account servicing payment service providers (ASPSPs) to immediately provide, upon request, payment service providers with a confirmation in a simple ‘yes’ or ‘no’ format, whether the amount  necessary for the execution of a payment transaction is available on the payment account of the payer. Paragraph 25 of the EBA Opinion on the implementation of the RTS on SCA and CSC (EBA-Op-2018-04) clarified that the ASPSP, in determining whether to give a yes or no response to the request for confirmation required under Article 36(1)(c), needs to determine whether or not there are funds available, taking into account not only the balance available but also any overdraft and also any other data that the ASPSP uses to determine whether or not to execute a payment of one of its own customers, for instance any incoming/outgoing payments that will affect the balance or overdraft. Therefore, if the ASPSP takes into account batch payments that are in the queue waiting to be processed when deciding whether or not to execute a payment initiated directly by the payment service user PSU, the ASPSP should also take into account such batch payments when providing a confirmation of funds to a payment initiation service provider in accordance with Article 36(1)(c) of the Delegated Regulation.