Sweeping VRP
The following provides details on how you can create a Sweeping Variable Recurring Payment instruction and then make unattended payment requests to transfer funds from the individual's customer account into another customer account owned by the same individual.
The term ‘Sweeping’ refers to the automatic transfer of funds between an individual's own accounts. This can include moving money from a current account to a savings account, or between accounts to manage liquidity and ensure optimal interest accrual or debt repayment.
For a VRP transaction to be able to meet the definition of “Sweeping” it needs to meet the following criteria:
The source account needs to be a PCA (Personal Current Account) or BCA (Business Current Account).
PCAs or BCAs which require multi-authorisation are explicitly excluded from the definition. Joint accounts typically do not require multi-authorisation as both parties have full authority to make payments and so would be included in the definition.
The destination account is an account into which a domestic payment can be made by the payer’s bank’s direct channel.
Both accounts are UK sterling accounts.
The payment can be an unattended payment, not requiring any interaction by or presence of the account holder at the time of making the payment.
The transaction is between two accounts belonging to the same person or legal entity.
More guidelines published by Open Banking limited can be found here: https://standards.openbanking.org.uk/good-practice/vrp-for-sweeping-guidelines/latest/
VRP Instructions
The following APIs allow you to create and manage a VRP instruction. Your API Subscription Key must be specified in each request using the Ocp-Apim-Subscription-Key header and the request body should be in the format of application/json.
Create a VRP Instruction
To create a VRP Instruction, you will need to send a Create a VRP Instruction API Request containing: payee details including bank account details, and the amount threshold details as described below. A synchronous response containing the result of the request is returned including the instruction id if successful.
Important Note: Amount Thresholds
VRP Instruction Consent allows you to define the maximum single transaction value that you sweep from the customer account. It also allows you to set interval amount thresholds, for instance, a daily cap could be £500, with a monthly limit of £5000, and an annual threshold of £25,000. Under this arrangement, payments could total up to £500 within any 24-hour window, not exceeding £5000 in any month, and £25,000 annually.
You must exercise caution when defining VRP Instruction Consent amount thresholds, particularly regarding the maximum allowable transaction value.
Setting thresholds that are too broad may raise questions about the adequacy of instruction consent under the Payment Services Regulations (PSRs). The PSRs mandate that VRP Instruction Consents be "explicit", emphasising the need for them to be specific, informed, and unequivocally granted. Broadly set parameters could, in a dispute or regulatory scrutiny, lead to a determination that VRP Instruction Consent was not valid. In instances where transactions are deemed unauthorised due to inadequately narrow VRP Instruction Consent amount thresholds, you would be responsible for compensating the Account Servicing Payment Service Provider (ASPSP), should they refund the customer.
We recommend that you regularly assess the VRP Instruction Consent amount thresholds and closely monitoring the gap between actual transactions amounts and your defined thresholds. This will ensure that VRP transactions are regulatory compliant but also improves the protection for both you and your customers reducing the risk of payments being disputed.
For details on how to Create a VRP Instruction, refer to the detailed API Documentation.
Get a VRP Instruction
To receive details on a VRP Instruction, send a VRP Instruction GET Request that contains the instructionId. A synchronous response is returned containing the instruction's details including amount thresholds, status and payee details.
For details on how to Get a VRP Instruction refer to the detailed API Documentation.
Cancel a VRP Instruction
To cancel a VRP Instruction Consent, you will need to send a Cancel request containing the instructionId that you wish to cancel. A synchronous response containing the result of the request is returned and if successful the VRP Instruction will be flagged as cancelled.
For details on how to Cancel a Payment Instruction, refer to the detailed API Documentation.
Confirm Available Funds
Prior to making a sweeping Variable Recurring Payment, you may wish to check that the customer has the available funds, this can be done by sending us a Confirm Funds API request. A synchronous response containing the result of the check is returned with a status of Available or Not Available.
For details on how to Confirm Available Funds, refer to the detailed API Documentation.
VRP Payment Requests
The following APIs allow you to initiate a sweeping Variable Recurring Payment from an individual's customer account into another customer account owned by the same individual, then the VRP Payment request must contain the instruction id containing the customer consent.
Before initiating a VRP payment request, you must verify that it does not exceed either the maximum single amount limit or any interval amount thresholds.
Initiating a payment which is outside of the thresholds, e.g. exceeding the single amount limit or an interval amount threshold will be deemed as attempting to initiate a payment without the customer’s authorisation and is likely to be Rejected.
Create a VRP Payment Request
To make a VRP Payment, you will need to send a Create a VRP Payment API Request containing: VRP instruction Id and the amount that is within the threshold rules. A synchronous response containing the result of the request is returned including the payment id if successfully received.
For details on how to Create a VRP Payment Request, refer to the API Documentation.
Get VRP Payment Details
To receive details on a payment, send a VRP Payment Details GET Request that contains the PaymentId. A synchronous response is returned containing the payments details including amount and status of the payment request.
For details on how to GET Payment Details, refer to the API Documentation.
Instruction Consent Management
It is a regulatory requirement that you must provide your customers with an interface for them to view and cancel ongoing VRP Instruction Consents.
The Instruction Consent Management Interface must comply with the following principles set out the Open Banking standards:
Easy to Find and Locate. The first principle emphasises the importance of easy accessibility of the Instruction Consent Management Interface. The interface should be prominently placed within your domain, with minimal clicks required from the home page. The name and location within navigation menus should be user-friendly, avoiding technical jargon. Providing clear explanations or tutorials for new customers ensures awareness of the Instruction Consent Management Interface’s existence and functionality.
Intuitive to Use and Understand. This principle focuses on the user experience, emphasising that the Instruction Consent Management Interface should be designed intuitively. Users should have easy-to-understand controls that empower them to manage their VRP Instruction Consents effortlessly. While the specific design may vary, the interface must ensure that users are well-informed about and capable of managing their VRP Instruction Consent connections effectively.
Be as Transparent as Possible. Transparency is key in the design of the Instruction Consent Management Interface. While avoiding information overload, the interface should provide users with comprehensive details about their VRP Instruction Consent’s arrangements. This includes clear information on past and ongoing activities, as well as any involvement of other parties. The goal is to be as transparent as possible, promoting user trust and understanding in the Open Banking ecosystem.
For further details on the Instruction Consent Management Interface guidelines, please review: https://standards.openbanking.org.uk/customer-experience-guidelines/dashboards/vrp-consent-dashboard-revocation/latest/
Recommended Instruction Consent Management Interface Elements
To be effective and compliant, the Instruction Consent Management Interface must display several essential elements to your customers
Overview of Instruction Consents: The interface should provide a clear and comprehensive overview of all the instruction consents that the customer has granted.
Status of Each Instruction Consent: For each instruction consent, the interface must show its current status - active, expired, or cancelled. This helps your customers quickly understand which instruction consents are currently allowing data access and which are not.
Detailed Instruction Consent Information: Each instruction consent must include detailed information such as:
The date of instruction consent creation
The purpose for which the payments are being made
The expiration date of the instruction consent
The name of the customer’s account provider the consent is created with
The customers paying from Sort Code and Account Number
The Payee details
Date Last Payment was made
Total payments made to date
The Interval Amount Limits
Controls for Managing Instruction Consents: Customers should have the ability to easily manage their instruction consents. This includes option to cancel instruction consent. The process for cancelling an instruction consent should be straightforward and user-friendly.
Privacy and Data Security Information: Customers should have easy access to information about data privacy and security practices. This includes how their data is protected, their rights under data protection laws, and contact information for inquiries or complaints.
User Support and Help Resources: Lastly, the interface could include resources such as FAQs, help guides, or contact details for customer support, to assist your customers in understanding and managing their instruction consents effectively.
Cancelling an Instruction Consent
As part to your Instruction Consent Management Interface, you are required to provide the customer a clear and simple way for them to cancel/revoke their VRP Instruction Consent. The cancel process should have a simple ‘Cancel’ button on each of the screens that details the VRP Instruction Consent. When selected the screen should display a clear message confirming the cancellation and impact on the service you are providing the customer.