ECB Regulation Amendment on Payment Systems: What Changes in 2025

Key data

Operators of systemically important payment systems (SIPS) in the eurozone have an immediate obligation: to review the corrected text of the Regulation (EU) 2025/1355 of the European Central Bank, originally published on 14 July 2025 and now corrected by corrigendum published on 27 March 2026.

This correction does not introduce new regulation, but it does modify the current text. Any internal compliance procedure based on the original version may be outdated. For compliance and legal teams of these infrastructures, ignoring a corrigendum does not exempt them from compliance with the correct text.

What does this regulation establish?

Regulation (EU) 2025/1355, adopted by the ECB on 2 July 2025 under reference ECB/2025/22, establishes the prudential and supervisory standards that operators of systemically important payment infrastructures in the eurozone must comply with.

The regulation covers the supervisory requirements for systemically important payment systems (SIPS): those infrastructures whose malfunction could generate risks to the stability of the European financial system.

The corrigendum published on 27 March 2026 corrects material or formal errors detected after the original publication. This type of correction is common in complex European regulation and has full legal validity: the corrected text replaces the original in all its effects.

Economic and operational impact

The direct impact of this correction is operational and regulatory compliance, not economic in terms of new fees or sanctions introduced by the corrigendum itself. However, the consequences of failing to update internal procedures can be significant:

• Risk of non-compliance: If compliance manuals, internal policies or control systems are based on the original text with errors, the operator could be applying an incorrect version of the regulation.
• Supervisory reviews: The ECB, as supervisor of SIPS, may require evidence that compliance is based on the current and correct text.
• Cost of internal review: Legal and compliance teams of SIPS operators must dedicate resources to identifying which articles or sections have been corrected and updating internal documentation.

Since Regulation (EU) 2025/1355 establishes prudential standards for systemically important infrastructures, any deviation from the correct text may have implications for the ECB's supervisory assessments.

Who does it affect?

This regulation has a very specific scope. It does not affect ordinary companies, SMEs or self-employed individuals. The direct affected parties are:

• Operators of systemically important payment systems (SIPS) supervised by the ECB in the eurozone
• Compliance and legal teams of such operators, responsible for keeping regulatory documentation updated
• Risk and internal audit teams that assess compliance with the ECB's prudential framework
• External advisors providing compliance services to SIPS operators

Systemically important payment systems are large financial infrastructures, not standard payment services. These are platforms whose volume or interconnection with the financial system justifies their direct supervision by the ECB under this specific framework.

Practical example

An operator of a systemically important payment system has documented its compliance procedures based on the text of Regulation (EU) 2025/1355 published on 14 July 2025.

Following the publication of the corrigendum on 27 March 2026, its legal team must:

1. Download the corrected text from the Official Journal of the EU
2. Identify which articles or sections have been modified compared to the original version
3. Update internal compliance manuals that reference the corrected articles
4. Document the update process to demonstrate to the ECB that compliance is based on the current correct text

This process is standard in large financial infrastructures, but it requires resource allocation and a reasonable review period from the publication of the corrigendum.

What should companies do now?

1. Download the corrected text: Access the corrigendum published on 27 March 2026 in the Official Journal of the EU and obtain the updated version of Regulation (EU) 2025/1355 (ECB/2025/22).
2. Compare with the original text: Identify which articles, sections or references have been corrected compared to the version published on 14 July 2025.
3. Update internal documentation: Review and correct all compliance manuals, internal policies and control frameworks that cite or apply the regulation.
4. Inform relevant teams: Communicate the changes to those responsible for risk, internal audit and operations who apply the regulation's requirements in their daily work.
5. Document the process: Record the review carried out and the date of documentation update, to demonstrate to the ECB compliance based on the correct text.