Even though Open Banking and SEPA Request-to-Pay (SEPA R2P) pursued the same goal, very different paths were chosen.

With PSD2 and the Open Banking framework built on top of it, the EU hoped to drive a strongly growing adoption of low-cost SEPA account-to-account payments (A2A payments) in e-commerce. While Open Banking is already firmly established in the Baltics and Scandinavia, German retail still struggles with it. Why is that – and what has changed since the introduction of the Instant Payments Regulation? An updated analysis.

Open Banking versus SEPA Request to Pay

Even though Open Banking and SEPA Request-to-Pay (SEPA R2P) pursued the same goal, they took very different routes to get there.

Open Banking:

The foundation for Open Banking was laid by the new EU directive PSD2 in 2015, which was gradually transposed into national law. In simple terms, it obliged banks, among other things, to provide technical interfaces (APIs) to their systems. The expectation was a rapid rise in competition – the starting gun back then for the fintech race.
What sounded very promising in theory turned out to be a forced marriage in practice. Banks regarded Open Banking as a threat, and so many of them, especially the less digital ones, decided to offer their interfaces as well as necessary and as poorly as possible.
The resulting consequences were wildly inconsistent user experiences, which ultimately forced Open Banking providers to carry out customer identification on their own side. While this did create a uniform user experience, the average conversion rate dropped to 74% as a result, because customers do not want to enter their bank login details on third-party sites.
Another disadvantage: in the increasingly important field of mobile commerce in particular, Open Banking is an absolute “conversion killer”. On a smartphone, customers expect to pay with their banking app, but that app cannot be addressed through Open Banking. As a result, the mobile conversion rate can fall below 60%.

SEPA Request to Pay:

Unlike Open Banking, SEPA R2P is built on the principle of voluntary participation – every party was brought on board. SEPA R2P is a technical standard developed by the European Payments Council (EPC); however, unlike Open Banking, this time there is no legal obligation for banks to integrate it. Banks should regard SEPA R2P as an opportunity rather than a risk; they can set their own pace and thus stay in the driving seat.
With SEPA R2P, the invoice can be transmitted together with the payment request and is therefore shared directly with the customer who owes the payment – as part of the SEPA Request-to-Pay scheme. This significantly increases the efficiency of invoicing and also guarantees a 100% reconciliation rate by pre-linking the order with the outstanding payment.
SEPA Request to Pay relies on proven standards: XML for efficient data exchange and SEPA Credit Transfer for the flow of funds.

Request-to-pay: a win-win-win for customers, e-commerce merchants and banks

SEPA Request to Pay offers benefits to all of the key parties alike.

  • Banks move closer to their customers again. This strengthens customer loyalty while at the same time creating opportunities to offer value-added services such as Buy Now Pay Later, factoring or secured payments. The banking app thus becomes a wallet – and once again the central financial hub of the primary bank.
  • Customers gain a better overview and more control over their spending behaviour with SEPA R2P, because all payments come together in their banking app. The risk of losing track of different accounts and the finances associated with them is significantly reduced. The number of different apps needed for online payments with various providers also drops noticeably. On top of that, customers experience the security of their primary bank, which they generally prefer for financial matters. Their experience is tied to a high security standard and a great deal of trust – an essential aspect compared with non-EU services.
    And in future, customers will enjoy a seamless, perfect UX of the kind they know from established payment wallets.
  • Merchants benefit from sharply falling fees, because A2A payments involve fewer participants in the value chain. The better UX, especially in mobile commerce, drives stronger usage and a higher conversion rate. The resulting higher cart share delivers even greater cost savings at the same revenue. Thanks to its simplicity, SEPA R2P poses a serious challenge not only to Open Banking solutions but also to other payment methods such as direct debit and credit card. With SEPA R2P, the effort required to integrate a new payment method and to expand its usage is significantly reduced. On the e-commerce merchant side, integration can be done via APIs or the Gini plugin for native apps (SDK), for example. This keeps the entire integration process simple and cost-effective.

The state of play in 2026: the rails are laid – but banks still hesitate

Since the original analysis, the starting position has changed decisively: the EU Instant Payments Regulation is now in force. Banks in the euro area have been required to receive instant credit transfers since 9 January 2025 and to send them since 9 October 2025 – at prices that may not exceed those of standard transfers. In parallel, the free Verification of Payee (VoP) service has been mandatory since 9 October 2025, matching the payee’s name and IBAN before a transfer is authorized. This means exactly the real-time rails and the trust anchor that a scheme like SEPA R2P builds on are now available across the board. The EPC has also simplified the SRTP scheme with version 4.0 (in effect since October 2025) and lowered the barriers to entry.

So the technical precondition is solved – yet banks’ reticence remains the real brake. Industry analyses for 2026 clearly identify A2A as the trend, but note that only a small share of banks are both commercially and technologically ready to lead the way. The central obstacle is not technology but fragmented ecosystems and the lack of a strong commercial and political push to make A2A the default. In Germany and Austria in particular, legacy systems and entrenched structures slow progress. Unlike PIX, UPI or FPS, which benefited early on from mandatory participation, SEPA R2P depends on voluntary adoption – which explains the slower pace.

Why act now anyway – or precisely because of this: the field does not stay empty while banks wait. With Wero, the European Payments Initiative (EPI) has built a bank-owned A2A wallet that gained more than 40 million users for P2P payments in its first year and has been rolling out into e-commerce since the end of 2025 – first in Germany, followed in 2026 by Belgium, France, Luxembourg and the Netherlands, where iDEAL is migrating into Wero. This shows two things: A2A at the checkout is real and scales as soon as the participants pull in the same direction. And: any single bank that fails to occupy the direct A2A payment moment within its own app cedes that customer interface to a pan-European wallet – or continues to cede it to PayPal, which dominates the German online checkout with roughly a third of the market, simply because a strong domestic A2A offering has been missing.

For banks, the message is: the window to establish their own banking app as a payment point in retail is open – but it is closing. Those who set up SEPA R2P now defend the direct customer relationship; those who wait give it away.

Grafik R2P

SEPA R2P: strong interest on the customer side expected

On the consumer demand side, interest was high from the start – and the finding still holds: in a YouGov survey commissioned by Gini (October 2023), 54.3 percent said they would want to pay via SEPA R2P if the function were available in their online or mobile banking. One in five respondents (20.9 percent) would even be willing to replace their preferred payment method or provider with it.

Younger respondents show particularly strong interest: one in three of those aged 18 to 34 (33.4 percent) would completely replace their preferred payment method, compared with one in eight of those over 55 (12.5 percent). The survey demonstrates that SEPA Request-to-Pay is an attractive alternative to third-party solutions. The tension in 2026 is therefore clearly defined – customer demand is there, while the banks’ offering lags behind.

A positive impact on online retail

Paying is simply too expensive overall. Online merchants pay an average of around 2% of their revenue to payment service providers – for card and online payments, current industry analyses put fees closer to 2.25 to 2.5%, with a range of 1.5 to 3.5% depending on the card network and transaction type. While the EU caps the interchange fee at 0.3%, payments remain a substantial cost block in total – and providers have tended to raise their prices recently. While credit providers earn generous EBIT margins of over 60%, merchants usually have to get by on well under 10%.

SEPA Request-to-Pay will considerably reduce the complexity of the payment flow, increase competition, and thereby lead to drastically falling fees. Because banks know their customers’ creditworthiness best, the costs of payment defaults (risk management) will also continue to fall. High trust in banks, combined with the UX of a wallet, can in the medium term establish SEPA R2P as a new payment method with cart shares of more than 10% – provided banks use the instant-payments foundation that is now available before other A2A players take the space.

*The data used is based on an online survey conducted by YouGov Deutschland GmbH on behalf of Gini, in which 2,129 people took part between 17 and 22 October 2023. The results were weighted and are representative of the German population aged 18 and over.

Martin_Meinert

Martin Meinert

Director E-Commerce and Partnership bei Gini seit 2024. Leidenschaft für Payment und E-Commerce. Als Betreiber eines Online-Shops hat er tiefes Verständnis für beide Seiten, die Retailer und die Payment Provider.

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