For Italy, the post-SEPA process, which has been painstakingly completed in recent weeks (almost all wire transfers and almost 90% of direct debits have now migrated to the new format), will be characterized by two peculiar aspects, which risk allow us to reap the benefits of European standardization of payments only to a limited extent.
The two profiles, which differentiate us from other European countries, concern the size of the national market for payments other than cash and its composition. The instruments issued annually in Italy are in fact equal to just over four billion against almost twenty billion each in France, Germany and Great Britain.
If we then consider only the electronic payments of the Sepa world (debits, transfers and credit and debit cards) the number drops below three billion, given that, and this is the second point, the payment instruments that will not migrate there, continuing to have relevance only at the national level, i.e. cheques, postal payment slips, bank receipts and other amounts to over 1,2 billion a year.
These two peculiarities constitute as many structural misalignments with respect to the situation of our competitors and will tend to negatively influence the development of the Italian electronic payments market, if corrective measures, including legislative ones, are not implemented.
Ultimately, our country, presenting itself at the European appointment of SEPA and the Banking Union with three macro segmentations (cash, SEPA electronic instruments and domestic payment instruments), does not have the reasonable certainty of seeing the affirmation of the most efficient and secure Sepa tools.
At all costs, it is necessary to prevent them from being squeezed between cash on the one hand and postal payment slips and RiBas on the other, with an impact also on other renewal processes, essential to our country. Among these, electronic invoicing, although it has recently made progress, risks not being integrated with the more advanced payment flows.
So that the discrepancies on the payments side could create obstacles to the development of the digital economy itself on which the government is also strongly committed, as emerged during the Digital Economy Week, organized in Venice between 7 and 11 July last, which saw the participation of Prime Minister Renzi and European Commissioner Nelly Kreise.
In fact, what is the point of issuing an electronic invoice if the debtor then pays by bank receipt or cheque? Which of the two factors will determine the level of service: the digital one or the usual domestic payment card? And what will be the effects on prices? So what to do?
Firstly, the direction of the so-called cross-subsidy must be reversed, which today sees the pricing of electronic instruments implicitly subsidizing the hidden cost of cash. The use of electronic payments must be made attractive for the parties to any commercial transaction.
This option rests not so much on the imposition of quantitative limits on cash transactions or on more or less obligatory instruments such as the social card or the basic current account of the Monti government as much as on economic convenience: the question of prices is the real variable capable of impressing a radical change in the habits of the country.
Unfortunately, the signals in this sense are not only weak, but even contradictory, if in decree 51/2014, a commission charged to the user for electronic payments of fuel up to 30 euros is legitimized again. Even the pricing policies of intermediaries, resulting from the obligations for professionals to use Pos over 30 euros, do not appear particularly favorable for enjoying the benefits that technology makes available at rapidly decreasing production costs.
It must also always be remembered that overcharging (application of payment commissions for the purchase of goods or services) and double charging (double commission for a direct debit, one for collection and one for payment) charged to the final consumer, are prohibited by law. Coherent sanctioning policies are therefore desirable and the recent transposition in Italy of the Directive on Consumer Rights seems to go in this direction, which could also discourage practices, certainly not transparent, aimed, for example, at applying commissions on the accounting of payment.
It is increasingly necessary to differentiate payment services from other banking and financial services, making the payment account become a typical contract of the Italian legal system, which must be legitimized in every respect, civil and fiscal. Lastly, there remains the problem of domestic payment instruments such as postal payment slips which only a legislative provision could solve, directing them towards the European typification of bank transfers.
In short, despite the successful migration to Sepa, Italy still has a long way to go, with open questions that only coherent policies, which avoid uncertainties in the direction to follow, can help to resolve. Otherwise, the most advanced part of the payment system will only continue to debate between the Scylla of cash and the Charybdis of other domestic peculiarities, only to end up going backwards.
