The European payments landscape has fundamentally changed. After years of policy discussions and a final legislative push, Electronic Money Institutions (EMIs) and Payment Institutions (PIs) now have the right to direct participation in the Eurosystem’s TARGET2 (hereafter referred to as T2) payment system.
This change took effect on October 6, 2025, following amendments to the Settlement Finality Directive and the entry into force of Guideline ECB/2025/28. The extension of access rights supports the goals of the Instant Payments Regulation, promoting competition, efficiency, and innovation across the Eurozone.
The new framework is particularly relevant for payment service providers that handle large transaction volumes or operate across multiple settlement systems. From October 6, EMIs and PIs can have direct access to T2.
Benefits of Direct Access
For authorized non-bank PSPs established in the EEA, direct access to T2 represents a major shift, unlocking advantages that were previously exclusive only to banks:
- Payments are executed in central bank money, significantly reducing credit and settlement risk compared to using commercial bank sponsors.
- PSPs can now manage their liquidity independently without relying on commercial bank sponsors or third-party infrastructure.
- Participants can reach over 39,000 system participants directly, ensuring faster, more transparent and more operationally resilient payment execution.
- Utilizing the same core infrastructure as banks provides a high level of operational resilience, essential for high-volume processors.
Risk Management Principles for Direct Participants
Non-bank participants seeking to join the system must meet strict conditions designed to ensure that their participation does not create risks to financial stability.
Direct access is available to authorized PIs and EMIs established within the EEA. Access depends on arrangements within Member States that verify the adequacy of operational and risk management processes for non-bank payment service providers.
These institutions are not eligible for Eurosystem credit, and standard remuneration rules apply, min (0, €STR-20bp). Accounts are used exclusively for settlement purposes and cannot be used to safeguard users’ funds. Balances must remain limited to what is strictly necessary to meet settlement obligations.
Additionally, a maximum holding limit is defined for each participant to prevent liquidity concentration. This limit is typically set at twice the highest daily value of outgoing transfers over the past 12 months, and penalties apply if the limit is exceeded.
Furthermore, PSPs must demonstrate compliance with the same operational and technical requirements as existing T2 participants, ensuring consistency in reliability, security, and risk management standards across all participants.
Application Process
The official go-live date of October 6th means the application process is now fully open at National Central Banks (NCBs) across the Eurozone. Non-bank PSPs face a detailed procedure that combines general participation requirements with new obligations specific to their status:
Specific to non-bank PSPs:
- Provision of a statement issued by the relevant National Competent Authority or signed by the PSP’s management body, renewed annually.
- Submission of information required to determine the individual maximum holding amount.
Applicable to all participants:
- Installation of secured IT infrastructure.
- Provision of self-attestation confirming compliance with T2 security requirements.
- Submission of reference data forms, legal opinions and completion of certification tests.
Your Path to T2 Connectivity
To make the most of direct access to T2 Services, institutions need secure technical integration and ongoing operational resilience within the Eurosystem infrastructure. Achieving this requires expertise, compliance, and a reliable connection that meets the highest performance and security standards.
Inventi provides a Payment Gateway built for institutions that process large payment volumes and require central bank money settlement. The platform manages ISO 20022 messaging, security protocols, and Eurosystem connectivity testing, ensuring a smooth and compliant integration experience. By partnering with Inventi, PIs and EMIs gain direct access to T2, increase operational control, and can focus on service growth rather than infrastructure maintenance.
Contact us today to enable your connection to the T2 ecosystem with confidence.