SEPA in Luxembourg. Quick facts. International Bank Account Number (IBAN) IBAN structure. 56 SEPA Country Sheets - Luxembourg

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1 SEPA in Luxembourg Useful links SEPA migration, by Luxembourg Bankers Association ABBL (in French and English language) abbl Luxembourg web site Migration scenarios from legacy direct debits to the SEPA Direct Debits, ABBL download the PDF Mapping table of IBAN codes to BIC codes in Luxembourg, ABBL abbl Luxembourg web site codes page Quick facts International Bank Account Number (IBAN) IBAN structure Luxembourg IBAN accounts have 20 characters Country code 2 letters Check digit 2 numbers National Bank Code 3 numbers Luxembourg national legacy account number 13 numbers Position 1 and 2 Position 3 and 4 Position 5 to 7 Position 8 to 20 LU Source: RBS 56 SEPA Country Sheets - Luxembourg

2 Since 2002 all local Luxembourg banks have provided their account holders with IBAN account numbers and BIC codes on request. From 2005 it was mandatory to provide IBAN accounts for non-urgent domestic credit transfers in Luxembourg. Furthermore, since 9 October 2006 domestic and cross-border credit transfers and standing orders are processed as SEPA Credit Transfers (SCT) in the pan-european system STEP2 operated by the Euro Banking Association (EBA). As a result, currently all Luxembourg accounts are in IBAN format only, making SEPA implementation quicker, proved by the SCT adoption rate quoted above. IBAN conversion services Not required as currently all Luxembourg accounts are in the IBAN format only. Local payment delivery files Luxembourg legacy files that can be used until 1 February 2014 VIR2000 Flat file tag based DOM-2009 Flat file tag based DOM-Allégé CSV file For Luxembourg domestic and international urgent and non-urgent credit transfer transactions For Luxembourg domestic direct debits For Luxembourg domestic direct debits By 1 February 2014 at the latest you are required to use ISO XML (CGI) files as a replacement for your legacy files Source: RBS Payment instruments: convergence to SEPA Legacy payment instruments Domestic single and batch ACH payment SEPA payment instrument SEPA Credit Transfer International Standard Payment (in SEPA zone and in euro) Legacy collection instruments Domestic direct debits (DOM-2009 or DOM-Allégé) SEPA collection instrument SEPA Direct Debit (SDD) Core or SEPA Direct Debit (SDD) Business to Business Source: RBS 57 SEPA Country Sheets - Luxembourg

3 Derogations Derogation Applicable Date Applicable Significance for you Translation from BBAN to IBAN Start End No official information At the time of writing no official information has been published. Check latest information at European Central Bank site Niche products Start End ISO XML Start End IBAN and BIC Start End Source: European Central Bank No official information No official information No official information At the time of writing no official information has been published. Check latest information at European Central Bank site At the time of writing no official information has been published. Check latest information at European Central Bank site At the time of writing no official information has been published. Check latest information at European Central Bank site Comparison on legacy and SEPA Credit Transfers Comparison on legacy and SEPA Credit Transfer Scheme is not applicable in Luxembourg, as LIPS-Net (the former retail payment system in Luxembourg) stopped its activities in Following which, most banks in Luxembourg chose to migrate to EBA/STEP2. Banks not migrated to STEP2 consequently use other means of settlement for their retail payments (e.g. bilateral clearing). Additional optional service in Luxembourg At the time of writing there are no additional optional services known in Luxembourg. SEPA Direct Debit (SDD) management Creditor Identifier for SDD Luxembourg SEPA Direct Debit Creditor Identifiers have 26 characters Country code Check digit 2 numbers Business code (set yourself) 3 letters Fixed value 0 (zero) Luxembourg National Identifier1 18 alphanumeric positions Position 1 and 2 Position 3 and 4 Position 5 to 7, default ZZZ Position 8 Position 9 to 26 LU 12 ZZZ 0 ( )1 58 SEPA Country Sheets - Luxembourg

4 Notes: (1) For the 18-character National Identifier, it is possible to re-use 18 characters of an existing identifier, which will be encapsulated in the SEPA Creditor Identifier. If the existing identifier is less than 18 characters, the identifier is padded with 0 to reach 18 characters. If there is no re-use of an existing identifier, then an incremental SEPA Creditor-ID is generated, starting from and ending with Source: European Payments Council In Luxembourg, your SDD Creditor Identifier can be requested from RBS. The Creditor Identifier will be created by the Luxembourg Bankers Association, based on a request from RBS. Comparison of legacy and SDD Scheme DOM-2009 DOM-Allége SEPA Direct Debit Core SEPA Direct Debit Business to Business File format Flat file tag based CSV file XML Pain XML Pain Supportive of SDD No Yes Yes Debtor and creditor account details IBAN accounts (NB does not include BIC codes) IBAN accounts and BIC codes IBAN accounts and BIC codes Eligible debtors Consumer and business, but only in LU Consumer and business, in 32 SEPA countries Business only, in 32 SEPA countries Micro enterprise Not applicable Not applicable Seen as Business Mandates Managed and archived by debtor bank Creditor holds a paper version Creditor and debtor banks hold a paper version Mandate migration Yes, to Core or Business to Business, for details see legacy mandate migration section Yes, from legacy Yes, from legacy Mandate check by bank Checked for presence by debtor bank Not required Obliged to check every transaction against the mandate, before debiting Frequency Recurring One-off and recurring One-off and recurring Delivery timelines for debit on day D D-2 D-5 for first/one-off D-2 for recurrent/last D-1 59 SEPA Country Sheets - Luxembourg

5 RBS cut-off time on delivery day* Not applicable as RBS does not offer this product 09h00 CET (from June 2013) 09h00 CET (from June 2013) Pre-notification timelines Required, but no timeline specified 14 calendar days prior to day D unless otherwise agreed with debtor 14 calendar days prior to day D unless otherwise agreed with debtor Refund rights Consumers: 8 weeks after D Businesses: none (13 months for unauthorised debits) Consumers: 8 weeks after D Businesses: 8 weeks after D (13 months for unauthorised debits) Businesses: none (13 months for unauthorised debits) Returns (by debtor bank) Reversals (by creditor) RBS does not offer this product, no information available RBS does not offer this product, no information available From D to D+5 From D to D+2 From D to D+5 From D to D+5 Clearing and settlement National clearing or bilateral EBA/STEP2 EBA/STEP2 *Cut-off times are applicable for those formats/channels that support legacy scheme in the country. Source: RBS Reason code usage Although there is no explicit law prohibiting application of one or more of the reason codes in R-transactions in Luxembourg, it is at the discretion of each bank whether or not to specify the precise reason of the reject/return (e.g. insufficient funds) if the usage of such code is felt to be detrimental to their customers. Exception handling of legacy Direct Debit collections In relation to legacy collection files initiated prior to the migration end date and resulting in exception (R-transaction) after 1 February 2014, we know the following. Although the CETREL DOM-2009 system will no longer enable collections to be initiated after 31 January 2014, return- DOM files corresponding to original files initiated prior to 1 February 2014 will still be managed within the necessary time frame. 60 SEPA Country Sheets - Luxembourg

6 Mandate management Legacy mandate migration Legacy mandate for DOM-2009 direct debit collections can be migrated to SDD Core or Business to Business mandates. So, from now on until 1 February 2014 you have a choice of: 1. Migrating all legacy mandates to SDD Core, including mandates signed by a professional debtor (and for which collection is currently done with no refund right, i.e. the collection is known as non-refundable by the debtor bank). Although technically possible, the migration of mandates signed by a professional debtor to SDD Core Scheme may be not always desirable because of the refund right of eight weeks on a no questions asked basis, which is applicable in the SDD Core or 2. Migrating legacy mandates signed by a consumer debtor (and for which the collection is currently done with the conditional right to reimbursement, i.e. the collection is known as refundable by the debtor bank) to SDD Core and Migrating all or part of the legacy mandates signed by a non-consumer debtor (and for which the collection is currently done with no refund right, i.e. the collection is known as non-refundable by the debtor bank) to SDD Business to Business. In the event of migration to Business to Business, there is no obligation on the part of the debtor s bank to request confirmation of the mandate. Luxembourg legacy direct debit scheme follows Debtor Mandate flow, meaning that the debtor bank keeps the original paper mandate and performs a mandate management function. Under SDD, mandate management becomes the responsibility of the creditor. Therefore, to manage the migration from Debtor Mandate flow (legacy) to Creditor Mandate flow, ABBL (Luxembourg Bankers Association) set out a process, rules and timelines which need to be strictly followed by all participants. Key elements of this migration are summarised below. 1. Prior to the mandate migration, creditor needs to send a request to the various (debtor) banks so that they may confirm the accuracy of data relating to the existing mandates for debtor clients. This requests needs to be sent using the procedure and format described in the document (in French) by Cetrel S.A. Format des Fichiers Mandats pour migration.doc. Please follow the link below to access the document. wysiwyg/cetrel%20-%20format%20des%20fichiers%20mandat%20pour%20migration%20 v1-5.pdf. 2. Migration of mandates is communicated by the creditor in the first SDD collection. Two fields in the FIRST SDD collection are used to provide information that detects a mandate as 61 SEPA Country Sheets - Luxembourg

7 migrated 2.31 EndToEndIdentification and 2.49 DateOfSignature Determining the status of a mandate (i.e. whether it is migrated or not migrated ) shall be the responsibility of the debtor s bank, based on the FIRST SDD collection as stipulated above. The migration of a mandate is irrevocable. This means that a return to the DOM-2009 system will no longer be possible. As such, from the time when a creditor migrates the mandate of a given debtor, all subsequent presentations of this same mandate must go through the European SDD system. Mandates covering more than one service (e.g. monthly direct debits for a service and annual direct debits for another service), shall be migrated for all services at the same time. 3. Creditors and banks process SDD collections regarding migrated mandates (which have not experienced any change/amendment) based on the original mandate signed prior to 1 February 2014 and held at the debtor s bank (i.e. following legacy debtor mandate flow). 4. Any change (within the meaning of Mandate Amendment Procedure) of a migrated mandate must be done in accordance with the rules set out in this SDD manual. For all collections subsequent to such a change, the burden of proof for the debtor s consent falls on the creditor; therefore, in the event of a disputed collection, it shall be the responsibility of the creditor to prove the existence of a valid mandate. (i.e. following SDD Creditor Mandate flow). 5. However, from 1 January 2018, in the event of a dispute (i.e. unauthorised refund) on SDD Core collection (based on migrated mandates that have not been modified, point 3 above), the creditor must prove the existence of a valid mandate. This will complete the migration to the SDD Creditor Mandate flow. First SDD Core Collection Instruction Important send collections directly to the creditor bank(s) instead of to CETREL (local direct debit operator). There are two cases which determine the content of the fields in a migration FIRST file in different ways: 1. First case (suggested solution) The creditor requests a SEPA Creditor-ID including their DOM2009 CETREL creditor 62 SEPA Country Sheets - Luxembourg

8 identifier (i.e. they give a pseudo-iban format to their current identifier) and the creditor keeps their current registration numbers. In this case to migrate your mandates, you create a FIRST SDD collection with the following characteristics: Field 2.27 CreditorSchemeIdentification This field includes the new SDD-Creditor-ID (e.g. LU13ZZZ ), in which the Creditor-ID DOM2009 CETREL is included. Field 2.31 EndToEndIdentification This field shall take the value MIGRATION followed by the Reference at the creditor s choice. Note: New-Multiline shall not impose any controls for this field. However, the value is precalculated (timestamp), but can be modified by the user. The creditor should therefore perform the modification as set out above in the event of manual coding. This field notifies the debtor of the DOM2009 migration. Field 2.48 MandateIdentification This field includes the registration number, which remains unchanged. Field 2.49 DateOfSignature This field shall take the value Note: The special value in this field is not limited to the migration FIRST file, but is kept for subsequent collections. 2. Second case If either of the two conditions or both the conditions set out in the first case above are not respected, you shall be obliged to make a migration FIRST collection using the AmendmentIndicator = TRUE flag, with the following characteristics: Field 2.27 CreditorSchemeIdentification This field includes the new SDD-Creditor-ID (e.g. LU83ZZZ ); this may be for example an incremental identification number or an identification number containing the VAT number or the trade register number. Field 2.31 EndToEndIdentification This field shall take the value MIGRATION followed by the Reference at the creditor s choice. Note: New-Multiline shall not impose any controls for this field. However, the value is precalculated (timestamp), but can be modified by the user. The creditor should therefore 63 SEPA Country Sheets - Luxembourg

9 perform the modification as set out above in the event of manual coding. This field notifies the debtor of the DOM2009 migration. Field 2.48 MandateIdentification This field includes the new registration number (if the value has changed) or the former registration number (if it remains unchanged). Field 2.49 DateOfSignature This field takes the value Note: The special value in this field is not limited to the migration FIRST file, but is kept for subsequent collections. Field 2.50 AmendmentIndicator This field takes the value true and is followed by information in field Field 2.51 AmendmentInformationDetails This field includes the list of mandate elements which have been modified. Fields 2.52 and 2.53 are mandatory if their value has been modified. Field 2.52 OriginalMandateIdentification This field includes the value of the former mandat-id; If the coding is performed via New- Multiline, this latter will automatically place the word MIGRATION in front of the former mandat-id. Field 2.53 OriginalCreditorSchemeIdentification This field includes the value former creditor-id (CETREL or bilateral). Additional mandate requirements The following table shows a comparison between the most common fields used in Luxembourg legacy mandate and SDD Mandates. Mandate DOM-2009 Fields SDD Fields Mandate DOM-2009 Fields SDD Fields Unique Mandate reference Mandatory Mandatory (legacy DOM registration number can be used) Name of the debtor Mandatory Mandatory Address of the debtor Present Optional 64 SEPA Country Sheets - Luxembourg

10 Mandate DOM-2009 Fields SDD Fields Postal code/city of the debtor Present Optional Debtor s country of residence Present Optional Debtor s account number IBAN Mandatory Mandatory The BIC code of the debtor bank Not used, 4-digit bank code is used instead. See below for a link to the translation table from bank codes to BICs Mandatory Creditor company name Mandatory Mandatory Creditor s identifier Mandatory Mandatory (DOM2009 CETREL number can be encapsulated) Creditor s address street and number Present Optional Creditor s postal code and city Present Optional Country of the creditor Present Optional Type of payment Not used Mandatory Signature place Not used Optional Date and signature(s) Mandatory must be used for migrating mandates Additional attributes for information only Debtor identification code Not applicable Optional Name of the Debtor Reference Party Not applicable Optional Identification code of the Debtor Reference Party Not applicable Optional Name of the Creditor Reference Party Not applicable Optional Identification code of the Creditor Reference Party Not applicable Optional Underlying contract identifier Not applicable Optional Contract description Not applicable Mandatory Source: RBS RBS offers you translation and enrichment of your legacy mandates to SEPA standards, as well as a full life cycle mandate management tool, as part of RBS SEPA Accelerator. To learn more about these services please contact your RBS representative. 65 SEPA Country Sheets - Luxembourg

11 rbs.com/mib