instaSEPA is not a company. instaSEPA is an open market-coordination initiative to promote the SRTP scheme and an NFC for IP@POI technical implementation under one public-domain brand: “instaSEPA accepted here”.

Malta can run POS retail payments on SEPA, and be an example for other EU member states.

Every euro-area citizen already has the rails to pay directly from a bank account. The market still needs coordination to use these rails at the till and the checkout. This paper proposes that Malta coordinate its banks, payment institutions and fintechs around standards Europe has already published: EPC QR codes and SEPA Request-to-Pay, settled by SEPA Instant Credit Transfer. Payments in Maltese shops and on Maltese websites can then run on SEPA instead of international card networks.

Discussion draft for consultation · prepared for the Malta Financial Services Authority and the Central Bank of Malta · contributed by smartIBAN, a Malta-license applicant, as a member of an open working group.

The proposed mark: the SEPA identity with insta on top of it.

Proposal summary

Malta can be the example where every citizen uses their own banking app in a shop: tap via NFC and pay in a matter of seconds, with the same user experience as card payments, while the funds originate from one SEPA IBAN and are credited to another SEPA IBAN maintained at a different bank.

The EU has mandated instant payments and published the standards to initiate them at the point of sale. For our context, the size of the ecosystem in Malta, small but connected, brings the opportunity to execute easily the coordination between the two sides of the market: i) have all the banks & PIs support SEPA-NFC & QR-code, and ii) bring the physical-shop & ecommerce merchants on board too. We propose a measured pilot, coordinated by the MFSA and the Central Bank of Malta and built by the market. The result would be a blueprint other member states can copy, and a concrete Maltese contribution to the EU's payments strategic-autonomy agenda.

No new scheme. No new clearing house. No proprietary network. Just adoption of standards that already exist, at island scale, where coordination is achievable.

Why now

Three things changed in the last two years:

Instant settlement is now mandatory infrastructure. Under the Instant Payments Regulation, euro-area PSPs must receive SEPA Instant Credit Transfers and must offer Verification of Payee since 9 October 2025.
The standards to trigger those payments at a till or checkout are published. The EPC QR code for mobile-initiated SEPA (Instant) Credit Transfers and the SEPA Request-to-Pay scheme are public.
The window to lead is open, and it will not stay open long. Wero is live in Belgium, France and Germany, with point-of-sale NFC planned from H2 2026. The EuroPA alliance and EPI signed an MoU in February 2026 to build pan-European interoperability for about 130 million users. Malta can be first to ship an open, non-proprietary, standards-only implementation that other member states can replicate.

Built on published standards

An open payment experience built only on published European Payments Council work:

SCT Inst · settlement

The instant SEPA credit transfer. Funds move IBAN to IBAN in seconds, with a scheme maximum of 10 seconds. No card authorisation network.

EPC QR code · EPC024-22

Encodes beneficiary, IBAN and amount at the till or checkout. The customer's own bank app scans it and pre-fills the transfer.

SEPA Request-to-Pay · EPC014-20 v4.0

The target state for request messaging. The payee sends a structured request, and the payer approves it in their own bank app.

Verification of Payee · mandatory since Oct 2025

Confirms that the payee name matches the IBAN before the payer approves. This check is the primary fraud control.

Proximity · NFC tap

The buyer's banking app emits a unique IBAN over NFC at the till, through host-card emulation. The QR code is the fallback.

Virtual IBANs · acquiring side

Merchant collection IBANs with a virtual-IBAN layer, in house or via a PSP, for per-terminal and per-checkout reconciliation.

The design does not require a new scheme rulebook, a new clearing house, a proprietary wallet, exclusive rights for any single fintech, or coordinated pricing.

Who gains what

Citizens

Pay from their own bank account, in the banking app they already have. No new wallet, no card number, no foreign network in the critical path. Approval uses their bank's own strong customer authentication, and the payee is verified before they approve.

Merchants

Instant, final settlement to a SEPA IBAN. There is no batch clearing. One acceptance brand (instaSEPA or just SEPA) across physical retail and ecommerce.

Banks and PSPs

The customer relationship and SCA stay in the IBAN issuer's own app. Each acquirer and PSP sets its own pricing. A new opportunity to monetise SEPA transactions at scale: a revenue-share scheme (SEPA Interchange), where the acquirer of the SEPA transaction shares the revenue with the payer's IBAN issuer.

Malta

Malta becomes the reference implementation for SEPA at the point of sale. A jurisdiction that proves this attracts payment companies that want to build on it. The EU now looks for an example on payment sovereignty and a small country with a coordinated market can take this role.

How the funds flow

The customer pays only the shop price. The merchant receives an instant credit to a SEPA IBAN. The diagram shows an illustrative commercial example.

The fee level and the splits in the diagram are illustrative only. Each acquirer and PSP sets its own merchant pricing, bilaterally and competitively. There is no scheme-set interchange and no coordinated fee, and the working group would explicitly exclude pricing, to stay clear of Maltese competition rules.

What happens on a tap for SEPA NFC pay

The diagram shows the target flow, with SEPA Request-to-Pay end to end.

The buyer holds the phone against the till. The banking app transmits a disposable unique vIBAN over NFC.

The till sends a Request-to-Pay to that unique vIBAN. The request contains the amount and the merchant name.
The issuing bank maps the unique vIBAN to the buyer's real IBAN account and shows the request in the banking app.
The buyer approves with strong customer authentication (SCA).
The issuing bank sends an SCT Inst transfer to the acquirer. The acquirer credits the merchant and confirms to the till.

One mark on every shop door

Customers must see one sign and know that they can pay, the same in-store and online. The instaSEPA mark is proposed as a shared acceptance brand, governed by the working group on open, non-discriminatory terms. It is available to every licensed player and controlled by no single company.

Accepted here

Tap & Pay with your banking app.

Consumer protection, competition and integrity

A national payments capability must be safe, lawful and fair before it is fast.

Irrevocability and disputes. SEPA Instant payments are final; there is no chargeback. Protection therefore comes before authorisation: Verification of Payee confirms the payee first, and PSD2 liability and refund rules apply to unauthorised or incorrectly executed transactions. Merchant refunds run as ordinary credit transfers.
Competition law. The coordination asked of the MFSA and the CBM is technical interoperability and standards adoption only, never price. There is no imposed interchange pricing and no coordinated fee split. We introduce a SEPA Interchange scheme as a structure and not at pricing level.
Data protection. The design applies GDPR data minimisation and purpose limitation. Strong customer authentication and credentials remain with the customer's own bank. No third party holds them.

What we propose to the MFSA and the Central Bank of Malta

We ask for a meeting to discuss this topic and the opportunity of a one-day technical roundtable with Malta's core domestic banks and the licensed PI community, hosted by the MFSA. The goal of that day is a term sheet for a feasibility study and a measured pilot in the MFSA FinTech Regulatory Sandbox.

No endorsement of any single vendor is implied or sought, and participation is open to every licensed player on equal, non-discriminatory terms.

A proposed path:

Working group and term sheet. The MFSA and the CBM convene; the market participates. Scope, governance and success metrics.
Technical specification, industry-led: EPC QR initiation, Verification of Payee, SCT Inst settlement, the SRTP migration path, and the consumer-rights note.
Issuer app support in the banks: QR scan, request receipt with SCA approval, and app-to-app return.
Acquirer and PSP acceptance at till and checkout, settled to SEPA IBANs, with virtual-IBAN reconciliation for clean per-terminal reporting.
A measured pilot in the sandbox with selected retail and ecommerce merchants, measured on time-to-pay, authorisation success, consumer experience, and merchant cost versus cards.
Publish the playbook: an open reference implementation other member states can copy.

If only some banks join. A minimum viable coalition of two core domestic banks plus the PI and EMI community is enough for a meaningful pilot. Customers of non-adopting banks can still pay with a standard SEPA Instant transfer to the same merchant IBAN.

What Malta wins

A working, island-scale demonstration that a member state can deliver open, sovereign account-to-account retail payments in production.
A concrete contribution to the EU's strategic-autonomy agenda on payments, aligned with the Eurosystem's and the Commission's retail payments strategies.
A magnet for high-quality payment institutions and infrastructure builders, in line with the MFSA's FinTech Strategy objective: Malta as an international FinTech hub.
A story larger than national interest: Malta as the open reference node for SEPA retail payments, the interoperable complement to Wero and EuroPA, and the model other member states can adopt.

See it work today

Live checkout demo

A web checkout with a real EPC QR code simulation and a fake SRTP simulation using bunq NL IBANs for payers.

Open the demo

Android tap demo

An Android APK that helps simulate the SRTP POC. The supermarket can accept an IBAN via NFC to send the SRTP to.

Download the APK

NFC tap video

A short video shows a simulated SRTP POC where an NL buyer pays for bananas via NFC in a supermarket.

A working reference experience exists and can be demonstrated live. The proposal is that Malta owns the national rollout under open standards.

Closing

Cards solved the user experience. SEPA already solved the money movement. Malta can join the two: openly, and first among the small states.

We ask the MFSA and the Central Bank of Malta to open a structured dialogue with Malta's banking and payments community on coordinated, open-standards adoption for retail and ecommerce payments, beginning with a single technical roundtable to scope a feasibility study and a sandbox pilot.