Resource center · Tax Transparency

CESOP: which payment records are in scope?.

CESOP is a counting exercise before it is a reporting one. Scope turns on where payer and payee are located, and on a threshold applied per payee, per provider, per quarter — not per transaction.

Q & A CESOP · European Union · payment data reporting REGREP Regulatory Team · Reviewed 2026-08-09

Which providers report

The obligation attaches to payment service providers as defined in the payment services framework: credit institutions, electronic money institutions, payment institutions and post office giro institutions. The definition is functional rather than reputational — a business that holds funds in its own name before allocating them to a beneficiary can be a payment service provider for these purposes even if it does not describe itself as one.

That catches marketplaces and platform businesses that operate their own settlement layer. It is the first scope question to settle, because everything after it depends on the answer.

What makes a payment cross-border

A payment is cross-border where the payer is located in one member state and the payee is located in another member state or outside the Union. Location is determined from the identifiers the payment instruction already carries — the account identifier for the payer, and for the payee the account identifier or, where the payee holds no account with the provider, another identifier such as a business identifier code.

The obligation splits by role. A provider records the payment as the payer’s provider or as the payee’s provider, and the reporting duty falls on the payee’s side where the payee is in the Union. Systems that store a single transaction row per payment have to derive the role before they can derive scope.

How the threshold is counted

Reporting is triggered where a provider makes more than twenty-five cross-border payments to the same payee in a calendar quarter. Four properties of that count cause most of the disputes:

It is per payee, per provider, per quarter. A payee receiving twenty payments through one provider and twenty through another crosses no threshold with either.
It counts payments, not value. There is no monetary floor, so a payee receiving small amounts frequently is in scope while one receiving a single large amount is not.
Payee identity must be stable. The same merchant appearing under several identifiers is counted as several payees, which understates the position. Resolving payee identity is the substantive work.
Once the threshold is crossed, the whole quarter is reported — every cross-border payment to that payee, not only those beyond the twenty-fifth.

What a record carries

Reported content
Group	Content
Reporting provider	Identifier of the payment service provider making the report, and the member state to which it is submitted.
Payee identity	Name, any value added tax or other tax identification number held, account identifier and address as recorded.
Payee location	The member state or third country derived from the identifier, with the basis on which it was derived.
Transaction	Date and time, amount and currency, whether the payment is a refund, the payment method, and the member state of origin.
Initiation	Whether the payment was initiated at the physical premises of the merchant, which changes how the record is read.

Refunds are reported and are linked to the payment they reverse rather than netted against it. Personal data on the payer is not reported — the framework is built around the payee.

Which member state you report to

A provider reports to the member state where it is a home provider, and separately to each member state where it operates as a host provider. A provider passporting into several member states therefore produces several files from one dataset, on the same quarterly cycle, each carrying only that member state’s payments. Building one file and filtering it per member state is the pattern that scales; building each independently is not.

Official sources

Primary instruments only. Each is named in full so the reference remains traceable even if a link moves.

Council Directive (EU) 2020/284 amending Directive 2006/112/EC as regards introducing certain requirements for payment service providersEUR-Lex · Directive · the record-keeping and reporting obligation
Council Regulation (EU) 2020/283 amending Regulation (EU) No 904/2010 as regards measures to strengthen administrative cooperation in order to combat VAT fraudEUR-Lex · Regulation · the central system and exchange machinery
European Commission, Directorate-General for Taxation and Customs Union — CESOP guidelines for reporting, schema user guide and frequently asked questionsEuropean Commission · message structure and validation · consult the current version

Questions, answered

Does a payee below the threshold with one provider stay outside scope entirely?

For that provider, yes. The count is per payee, per provider, per calendar quarter, so a payee spreading activity across several providers can stay below the threshold with each. The provider only assesses what passes through its own books.

Are refunds counted towards the threshold?

Refunds are reportable records in their own right and are identified as refunds rather than netted against the original payment. Treat the counting question as a scope decision to document, and confirm the treatment against the current guidelines rather than inferring it.

We are the payer's provider, not the payee's. Do we report?

The reporting duty runs with the payee side where the payee is located in the Union. A provider acting only for the payer keeps records but does not carry the same reporting obligation for that payment. Systems must therefore derive the role before applying scope.

How do we locate a payee with no account identifier?

The framework allows location to be derived from another identifier the instruction carries, such as a business identifier code. Record which identifier was used for each determination, because location is the field most likely to be questioned later.

REGREP is an independent software provider. This record explains a reporting framework in plain language and is not legal, tax or regulatory advice. Confirm scope, thresholds and submission dates with your competent authority before you file.

At a glance

Who reports: Payment service providers within the meaning of the payment services framework — credit institutions, electronic money institutions, payment institutions and post office giro institutions.
Legal basis: Council Directive (EU) 2020/284 amending the VAT Directive, with Council Regulation (EU) 2020/283 on the central system.
Test: Cross-border payments, counted per payee against a quarterly threshold.
Format: An XML message per member state, to the national tax authority, which forwards to the central system.
Cycle: Quarterly, with the submission due in the month following the quarter it covers.