NATIONAL SEPA MIGRATION PLAN. 17 th February 2012

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NATIONAL SEPA

MIGRATION PLAN

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CHAPTER 1 PREFACE 6

CHAPTER 2 FRAMEWORK FOR THE SEPA MIGRATION PLAN 7

2.1 Summary of the European SEPA Regulation 7

2.2 Points of departure 8

CHAPTER 3 MIGRATION SCENARIO PROPOSAL 10

3.1 Summary 10 3.2 Banks 11 3.3 Software suppliers 16 3.4 Wholesale SCT users 18 3.5 Small-business SCT users 20 3.6 Wholesale SDD billers 24 3.7 Small-business SDD billers 27 3.8 Consumers 30 3.9 Communication 32

CHAPTER 4 SET-UP OF SEPA MIGRATION IN THE NETHERLANDS 34

Annex 1 Dependency diagram 35

Annex 2 Timelines for completion of basic product range and other infrastructure 36

Annex 3 SEPA direct debit timelines 37

Annex 4 List of abbreviations 38

Annex 5 List of organisations participating in the NFS 39

The present National SEPA Migration Plan has been drafted and adopted by the National Forum on SEPA Migration or NFS, where stakeholders in the non-cash payment chain come together to agree on the preparation, coordination and implementation of the migration to a European payment system. The Migration Plan, a co-production by and for NFS participants, aims to promote the smooth and efficient migration to SEPA credit transfers and direct debits, which according to the EU SEPA Regulation must be completed on 1 February 2014. The migration to SEPA payment instruments will require considerable efforts from all parties involved: banks, software suppliers, wholesale and small-business users of the payment system, and supporting parties. The Migration Plan records the changeover dates set for several groups of users and the deadlines by which banks and software suppliers must have payment products, infrastructure and software ready to enable users to make the changeover.

The Plan also presents agreements on actions to be undertaken by umbrella organisations to smoothe the migration process. The role of these umbrella organisations is crucially important: they supervise the migration of their constituencies and the NFS and actively disseminate the agreements made in the NFS. In doing so, they receive the support of the SEPA Netherlands Programme Agency (Programmabureau SEPA Nederland).

Getting the SEPA migration off the ground and going crucially requires adequate communication. Therefore, the Migration Plan also contains understandings on a centralised communication campaign, umbrellas’ communication to their constituencies and communication by businesses and organisations to their clients and customers. This way everyone, consumers and businesses alike, will receive timely and correct information on the changes implied by the transition to SEPA payment systems and instruments. The timelines set out in the SEPA Regulation are short. A joint effort is required to ensure the smooth, efficient and timely migration of all concerned in the Netherlands. Therefore, it is highly important that all parties concerned should pledge their commitment and do their utmost to make the deadlines stated in the Plan, so that on 1 February 2014 the migration to SEPA credit transfers and direct debits will be complete. F. Elderson

Chairman, National Forum on SEPA Migration

PREFACE

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The migration towards a Single Euro Payments Area (SEPA) has begun. It means that national payment systems and payment infrastructures must adopt European standards. The European SEPA Regulation imposes end dates on the migration of all national credit transfers and direct debits denominated in euro to European ones. After these end dates only non-cash retail payments based on common European standards will be permitted and there will no longer be any distinction between domestic and cross-border payments in euro. A broad-based approach at national level, including implementation timelines, is therefore urgently required. Under the timelines imposed by the SEPA Regulation, time for the mandatory migration to SEPA will be relatively short. In order to meet the timelines of the SEPA Regulation, the National Forum on the Payment System (MOB) has drawn inspiration from the euro migration a decade ago to set up the National Forum on SEPA Migration (NFS). Within the framework of the NFS, banks and other providers of payment services, large and small business users of payment services, software suppliers, consumers and intermediary parties can closely coordinate their activities in order to achieve a smooth migration. One of the first tasks of the NFS involves drawing up a national SEPA Migration Plan. The aim of the Migration Plan is to achieve a smooth changeover to European non-cash payments, taking account of the dependencies between the stakeholders in the migration process (see Annex 1). To this end, the Migration Plan sets timelines for the SEPA migration of broad groups of users. The Plan also indicates when banks and software suppliers will have their payment products and software ready to enable users to switch over. In addition, the Plan describes the actions that banks, users, software suppliers, intermediaries and umbrella organisations must carry out to ensure a smooth migration.

Scope and approach

The national Migration Plan sets timelines for the transition to European non-cash payments. The Plan thus focuses on the switch from the current national and cross-border credit transfers in euro to SEPA credit transfers and from national direct debits to SEPA direct debits. In order to achieve a targeted approach, the users are subdivided into three broad groups: consumers, large business users and small business users, with specific attention for billers. The Plan also devotes attention to the communication about SEPA migration and the role of intermediaries in the SEPA migration.

The Migration Plan is a co-production of and for the NFS participants and is aimed at facilitating the migration of the Dutch market. It draws on information obtained in meetings held with umbrella organisations of banks, businesses, consumers and public sector users as well as with a number of software suppliers, large businesses and large government organisations. It was also discussed in the Task Force SEPA Netherlands (TFSN). The national Migration Plan lays the foundation for informing members of industry organisations about the agreed migration timelines and the resulting actions for their members. The plan also incorporates the comments of the Netherlands Competition Authority (NMa).

Structure

The Migration Plan starts with underlying assumptions and aims. Next, the migration scenario is sketched: when will what users migrate, when are the payment products and software packages available to enable the mass migration of users, and what agreements must banks, users, software suppliers and intermediaries make with each other to carry out the migration scenario.

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2.1 Summary of the European SEPA Regulation

The European SEPA Regulation makes specific requirements of credit transfers and direct debits in euro. A precondition for every national migration is that it is conducted within the constraints of this Regulation. In the first place, the Regulation makes the use of European standards mandatory.

The main changes are:

• The International Bank Account Number or IBAN (the standard governing European bank account numbers)

• ISO 20022 XML (the standard for bulk delivery of payment and direct debit orders by business users)

A second requirement made by the Regulation is that European standards must be applied from

1 February 2014 at the latest. This means that from 1 February 2014, credit transfers or direct debits based on national standards, such as the current Dutch credit transfers and direct debits, must no longer be used. Because only the SEPA Credit Transfer (SCT) and SEPA Direct Debit (SDD), developed by the European banks, meet the European standards, the provisions of the Regulation imply that only these products can henceforth be used to transfer amounts in euro to or from another bank account.

The Regulation leaves the Member States free to apply a range of transitory measures:

• Until 1 February 2016, a Member State may permit payment service providers to offer conversion services enabling consumers to continue to use the legacy Basic Bank Account Numbers (BBAN). Such providers must effect the necessary conversion from BBAN to IBAN. The present Migration Plan1_{assumes that}

such a transitory measure will not be applied.

• Until 1 February 2016, a Member State may permit the authority supervising compliance with the Regulation to waive the requirement on payment service users to apply the ISO 20022 XML standard to deliveries of payment orders in batches. A Member State that uses this permission must also allow the supervisor to waive other requirements made of credit transfers and direct debits, where relevant. A Dutch supervisor of compliance with the Regulation has not been appointed as yet.

The present Migration Plan2 _{assumes that the waiver will not be used in the Netherlands.}

• Niche products3_{reported to the European Commission by Member States may continue to be used in}

their current form until 1 February 2016. Users of such niche products may migrate to European products at a later date (but no later than 1 February 2016). In 2012, the National Forum will decide on the use of niche products after the end date.

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Other relevant parts of the Regulation are concerned with:

• Business Identifier Code (BIC). Payment service providers must use BICs for mutual exchanges (unless the providers involved agree otherwise). From 1 February 2014 (for domestic transfers) or 1 February (for cross-border transfers), providers may not require users to state BICs. Until that date:

- billers must state the BIC of their bank on invoices, if required;

- payers must advise the payee of their bank’s BIC before the first debit takes place, if required. Member States may postpone the phase-out of the BIC requirement for domestic payments until 1 February 2016.

• The SEPA direct debit and consumer protection Payers have the right to instruct their payment service provider to:

- limit the direct debit collection to a specific amount or specific interval, or both;

- check, in the case where the right to a refund is excluded, whether the amount of the submitted direct debit transaction and the periodicity match the amount and/or periodicity agreed in the mandate; - to block any direct debits to the payer’s account or to block any direct debits coming from one or more

specified payees (‘blacklisting’) or to authorise direct debits only coming from one or more specified payees (‘whitelisting’).

2.2 Points of departure

The migration plan is based on the following points of departure: 1. A number of broad categories are distinguished:

• Banks • Software suppliers • Wholesale SCT users • Small business SCT users • Wholesale SDD billers • Small business SDD billers • Consumers • Intermediaries

2. For business users, SEPA migration takes place in two phases: a. Early movers are the first to switch over,

b. Mass migration to SEPA payment products.

3. A specific group of users can migrate to SEPA payments when SEPA payment products and SEPA-proof software are available to them.

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4. Banks phase in payment products to coincide with user groups’ preferred migration timing. Banks ensure timely adoption of specifications for their payment products.

5. Software suppliers offer SEPA-proof software in time to enable business users to migrate.

6. Billers can opt to migrate simultaneously to both the SEPA credit transfer and the SEPA direct debit. 7. The migration must be gradual to ensure a smooth transition. Banks are better able to support the

migration of their customers when they do not all switch over at the same time. This is particularly important to ensure that the often complex payments of large business customers are properly set up. By gradually increasing the volume with a limited number of parties, mass payments can be set up in a controlled manner. Testing and pilots will make a further contribution to a smooth migration.

8. The migration can be phased by means of a cascade approach. This means that the migration of a small number of large users will serve to introduce a large group of smaller users to SEPA payments. This will promote the migration of these smaller users. In addition, a distinction is made between SCT users and SDD billers. The migration of SCT users precedes the migration of SDD billers because the SCT is a simpler product and has been on the market longer than the SDD.

9. The migration to the SEPA direct debit will start on the basis of existing national agreements between banks and consumer organisations. This concerns the introduction of (selective) direct debit blocking and the introduction of alert services for consumers. In conformity with the regulation, the banks will offer the consumer protection measures described in the SEPA regulation no later than the end date for the migration to the SEPA direct debit.

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3.1 Summary

The figure below provides a summary of the proposed migration timelines for the various groups. For the business users, the figure only shows when the actual migration will take place.

Clearly, the preparations must be completed before this date.

Explanation:

• The ‘basic product range’ comprises the products that must be available before the start of mass migration. • Infrastructure means the payment products, the customer-bank and bank-customer channels, processing

by banks and processing by clearing houses.

• Migration means the final switchover by a user to the basic product range (i.e. SEPA credit transfer and SEPA direct debit). After the migration, the Dutch equivalents of these products will no longer be used.

CHAPTER 3 MIGRATION SCENARIO PROPOSAL

1-10 1-3 1-7 2012 2013 2014 Banks Software suppliers Wholesale SCT users Small-business SCT users Wholesale SDD users Small-business SDD users Consumers Communication Specification of basic product range for business users ready

Infrastructure ready for mass migration SDD meets Regulation’s consumer protection requirements 1 February: end date for migration to SCT, SDD

Adapting infrastructures to the demands of SEPA payment instruments Adaptation of packages

Migration support for users Migration support for users

Early movers Mass migration

Early movers Mass

migration

Early movers Mass migration

Increasing use of IBAN

Communication from umbrella orgs., intermediaries, Broad publicity campaign

Possible use of niche pr

oducts beyond end date

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3.2 Banks Product range

The following figures show how the SCT and SDD product range of the Dutch banks corresponds with the current Dutch product range.

Credit Transfer range

Netherlands

Internet-based credit transfer (domestic)

Cross-border Internet-based credit transfer (in euro, within Europe)

Paper-based credit transfer (domestic)

Paper-based cross-border credit transfer

(in euro, within Europe)

Standing order (domestic)

Urgent payment

iDEAL with domestic credit transfer

Digital invoice with Dutch credit transfer

‘Acceptgiro’ inpayment transfer

(Dutch) credit transfer by telephone

Internet-based SEPA credit transfer

Paper-based (standardised) SEPA credit transfer

SEPA standing order

IBAN-based urgent payment

iDEAL with SEPA credit transfer

Digital invoice with SEPA credit transfer SEPA Basic range Supplemen-tary range

Under discussion (see note)

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Notes

(a) SEPA credit transfer

• The SEPA credit transfer is available via Internet banking from all banks. In the fourth quarter of 2012, the majority of the banks will offer the SEPA credit transfer as the preferred option in the Internet banking environment. All banks will do this no later than the first quarter of 2013.

• The SEPA standing order will be available to users via Internet banking no later than the third quarter of 2012. • The paper credit transfer form will be made available from the fourth quarter of 2012 and by the first

quarter of 2013 at the latest. Not all banks will include paper credit transfer forms in their product range. Direct Debit range

Netherlands

One-off direct debit

(mandate: paper-based or by telephone)

Recurrent direct debit

(mandate: paper-based or by telephone)

B2B direct debit variants

Digital invoice processed through Dutch direct debit

Bulk delivery of Dutch payment/ direct debit orders

Gaming (no refund) direct debit

SEPA direct debit (paper-based mandate)

Digital invoice processed through SEPA direct debit

Bulk delivery of XML-based SEPA payment/direct debit orders via XML

SEPA

Basis assortiment

Aanvullend assortiment

Reporting on Dutch transactions

Wholesale payment range (businesses)

Netherlands SEPA

Reporting on SEPA transactions by XML/MT940

B2B SEPA direct debit

e-Mandate: SEPA direct debit with Internet-based mandate

Under discussion (see notes)

Current practice of Internet-based mandates

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(b) SEPA direct debit

There will be two basic types of SEPA direct debit:

1. The standard SEPA direct debit, which can be used for payments from private individuals, but also for direct debits between businesses,

2. The B2B SEPA direct debit, which can only be used for direct debits between businesses. The two types are identical in terms of basic concept and technical set-up. The differences lie in a number of product conditions and timelines. An overview is shown in Annex 3.

(c) Specifications

It is important to determine the specifications of the payment products in good time in order to ensure a smooth migration for business users. The specifications for SEPA credit transfers and direct debits are set out in the Rulebooks of the SEPA payments Council (http://www.europeanpaymentscouncil.eu). The specifications for batch deliveries of credit transfer and direct debit orders and reporting are laid down in the Implementation Guidelines for the Netherlands (http://www.sepanl.nl/index.php?p=915284). These implementation guidelines offer banks scope to determine their own specific approach to certain aspects. For large banks, the relevant specifications, related implementation guidance and individual procedures have been adopted and published via www.sepanl.nl. For smaller banks, these details will be finalised by 1 April 2012 and will be published on or before that date, also via www.sepanl.nl. All specifications qualify as regular, market conforming updates.

(d) Additional product range

The following applies to the additional product range:

Inpayment transfer

iDEAL

Digital invoice

Standard SEPA direct debit without refund

B2B direct debit

e-Mandates

Credit transfer by telephone

• The banks will provide clarity in the TFSN about e-invoicing after the Acceptgiro, no later than April 2012. In the first quarter of 2012, consultations will take place between banks and users (businesses and consumers).

• Specifications of the SEPA variant of iDEAL (v. 3.3) are available.

• From the second quarter of 2012, online retailers can switch over to the SEPA version of iDEAL. The deadline for their migration is the second quarter of 2013. During the dual period of iDEAL (from the second quarter of 2012 until the end of the second quarter of 2013) online retailers and (issuing) banks can migrate independently of each other.

• SEPA migration specifications are available.

• After consultation with business users, the banks will state their decision on the successor to the non-refundable direct debit in the first quarter of 2012. • Specifications are available from the bank.

• participating banks in the Netherlands (from EPC register): - ABN Amro

- Bank of Tokyo Mitsubishi - Deutsche Bank - Garantibank - ING - JP Morgan Chase - Rabobank - RBS • Dutch banks will add the e-Mandate to the SEPA direct debit, but it will not be made available to billers until after the end date.

• This concerns credit transfers made by speaking to a voice response system and/or keying in the instruction.

• In the first quarter of 2012, an expert meeting will take place of the Working Group on Availability and Accessibility and representatives of the banks.

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Action points

1. The smaller banks will follow the large banks by 1 April 2012 at the latest in determining their individual approach to the implementation guidelines and publishing it on their websites. The Dutch Banking Association (NVB) will publish information on specifications, implementing guidelines and references to bank-specific information as soon as this is available via www.sepanl.nl.

2. Each bank will ensure that its own infrastructure is ready for the migration of early movers and the mass migration of user groups, based on the timelines set out in this migration plan (as summarised in Annex 2). Banks will also ensure that the basic product range for each user group is available prior to their mass migration and offers at least the same level of user convenience as the comparable Dutch product range. Banks and clearing houses will jointly ensure that interbank processing is ready for the migration of early movers and the mass migration of user groups, based on the timelines set out in this migration plan (as summarised in Annex 2).

3. Each bank supports its customers with the migration to SEPA payments. This support will at least consist of:

• Provision of general information on SEPA payments, prior to the customer’s migration to SEPA payments; • Provision of specific information on the migration to SEPA payments tailored to the customer’s needs,

prior to the customer’s migration to SEPA payments;

• Assistance to help business users set up and connect (batch) deliveries of payments and reporting systems, including support for testing, throughout the migration period. At the request of their business customers, banks will work together with software suppliers at this stage.

• Advising billers planning to use the B2B SEPA direct debit that they must request new mandates from their invoicees.

• The IBAN BIC Service for converting account numbers, which the banks offer collectively.

Banks, business customers and software suppliers will jointly make arrangements for a smooth migration. 4. At the request of the SEPA Steering Group, the names of wholesale users of credit transfers and direct

debits will be provided to the SEPA Programme Agency. This will be done in strict confidence and within the frameworks of competition law, no later than February 2012, subject to the prior approval of the wholesale users concerned.

5. The SEPA Steering Group shares its aggregated migration monitor, including forecast for the coming three months, with the Programme Agency.

6. Every bank plans the migration of its customers in conformity with the timelines set out in this migration plan, as summarised in the schedule in section 3.1.

7. Banks will work together with consumer organisations to resolve any accessibility problems. During the migration period, they will communicate identified accessibility problems to the Programme Agency. 8. At the end of each quarter, banks will report individually to the Programme Agency on the progress of

the implementation of the action points for individual banks, using a reporting format drawn up by the Programme Agency.

4_{During the 2nd quarter of 2012, this information channel will be moved to the site of the Betaalvereniging,}

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9. NVB and the Betaalvereniging will:

• inform their board members about the NFS-approved migration plan and the resulting actions for their members by end-March 2012 at the latest, and will discuss the migration plan in the NVB/Betaal-vereniging first consultative Board meeting after the Migration Plan has been approved by the NFS; • by end-March 2012 at the latest, call on their members to implement the SEPA Migration Plan as approved

by the NFS and will, for the duration of the migration period, discuss the plan on at least a quarterly basis in their communications to their membership.

• ensure that members who are not represented in the SEPA Steering Group are kept abreast of the SEPA migration plan, partly through consultative meetings with these banks about the implementation of the SEPA Migration Plan at least once every six months until the end date of the SEPA migration; • inform their membership during the migration period on the outcomes of TFSN and NFS meetings,

in any case by forwarding the reports of these meetings without delay.

• report annually to the Programme Agency, throughout the migration period, about the implementation of the action points for the NVB/Betaalvereniging in the past year, starting with the report for 2012. The report will be supplied to the Programme Agency by the end of the first quarter at the latest. Migration issues

The banks reported the following migration issues (see also the issue list): • Importance of good communication (issue 9) • Consequences of the SDD consumer protection measures (issue 14) • Risks if the migration is not sufficiently gradual (issue 15) • Possibility that not all users are ready on time (17) • Availability of software packages (18) • The statement of BIC on invoices (20)

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3.3 Software suppliers Definition

The most important group of software suppliers for the migration to SEPA payment products comprises suppliers of business administration software and/or software for the exchange of payments and accountability information between businesses and banks.

Milestones

The most important milestones for software suppliers are:

1. The product specifications for batch delivery of payment orders (XML) and reporting (XML/MT940) have been finalised, except in the case of some smaller banks. For these institutions, the specifications will be adopted by 1 April 2012 at the latest.

2. Software packages will be ready for the basic product range by 1 October 2012.

3. The migration of business users is supported throughout the migration period, with emphasis on: a. the period from 1 October 2012 to 1 July 2013 for supporting the mass migration by wholesale

SCT users;

b. the period from 1 March 2013 to 1 February 2014 for supporting the mass migration by small-business SCT users;

c. the period from 1 January 2013 to 1 July 2013 for supporting the mass migration by wholesale SDD billers;

d. the period from 1 July 2013 to 1 February 2014 for supporting the mass migration by small-business SDD billers.

Cooperation between banks and software suppliers

Banks and software suppliers work together to ensure that migration issues are resolved quickly and smoothly. The Betaalvereniging has undertaken to disseminate information on specifications, implementation guide-lines and references to bank-specific information available through a central access point. For the largest banks, this information is already available on www.sepanl.nl; from 1 April 2012, it will also be put online for the smaller banks.

Action points

1. Software suppliers will adjust their packages to the requirements of the SEPA payment instruments and successfully test these in cooperation with banks by no later than 1 October 2012.

2. Throughout the migration period software suppliers must support the migration of their business customers with software and communication. Business customers, software suppliers and banks must work together to ensure a smooth migration.

3. ICT~Office will:

• inform its membership on the Migration Plan by end-March 2012 at the latest and will call upon members to carry out the migration plan and all ensuing activities;

• hold, in cooperation with the Programme Agency, meetings for software suppliers on at least a semiannual basis. These meetings will serve to compare notes, to answer questions about the SEPA migration, and to identify any commonly encountered migration issues and communicate them to the Programme Agency. The Migration Plan will be presented at the first of these meetings;

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• while the migration period lasts, inform its membership on the (relevant) outcomes of TFSN and NFS meetings;

• inform its members (in addition to the previous action points) at least four times a year during the migration period. For this purpose, ICT~Office will receive the toolkit that is being developed as part of the SEPA communication campaign;

• prior to every TFSN meeting during the migration period, report to the Programme Agency (like all other parties involved) about the progress made on the above action points.

Migration issues

Software suppliers mentioned the following migration issues (see also the issue list): • Availability of specifications for basic product range (issue 2)

• Central software test facility (issue 6)

• Importance of good communication (issue 9) • User-friendly IBAN BIC Service for SMEs (issue 10)

• Users still working with legacy software packages (issue 12) - Customers must contact their software supplier in time

- Customers must be aware that modifications may be included in underlying agreements. If not, supplementary agreements or paid upgrades may be necessary.

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3.4 Wholesale SCT users Definition

Wholesale SCT users are businesses / organisations that use only credit transfers for payments originated by them. The Wholesale SCT users jointly account for a substantial proportion of the total credit transfer volume. Business users belonging to this group will be informed by their banks. Wholesale SCT users are found in various sectors such as: government (including independent public bodies), salary processors and pension funds.

Milestones

The most important milestones in the migration of wholesale SCT users are: 1. Product specifications for the basic product range have been finalised

(for some smaller banks the finalisation deadline is 1 April 2012).

2. By 1 October 2012, software suppliers of wholesale SCT users will have their software packages ready for the basic product range.

3. Until 1 October 2012, early movers may migrate in consultation with their bank.

4. The infrastructure for the mass migration of wholesale SCT users will be ready no later than 1 October 2012.

5. The mass migration of wholesale SCT users will take place between 1 October 2012 and 1 July 2013. 6. Late movers will migrate between 1 July 2013 and 1 February 2014.

Availability of basic product range

The basic product range for wholesale SCT users consists of: • Internet-based SEPA credit transfer (B2B)

• Batch delivery of payment orders by businesses (XML) • Reporting (accountability) to businesses (XML/MT940)

The basic product range and other infrastructure will be ready for early movers before 1 October 2012. The infrastructure for the mass migration of wholesale SCT users will be ready no later than 1 October 2012. The additional product range consists of:

• Urgent payment

Banks and software suppliers offer support

During the migration to SEPA payment products, wholesale SCT users will work closely with their bank and software supplier, both in the preparation phase and during the migration period. Wholesale SCT users can use the IBAN BIC Service to convert their bank account files. Software suppliers can provide additional support in drawing up and implementing an appropriate action plan. In addition to these administrative adjustments, the migration also comprises technical changes in the delivery of payment instructions and the reporting process, where XML will be the new standard. Businesses, software suppliers and banks will carry out these technical changes in joint cooperation.

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Action points

1. Wholesale SCT users will migrate to the use of the basic product range for the SEPA credit transfer no later than 1 July 2013.

2. Wholesale SCT users that are yet to start preparing for the SEPA migration will perform at least the following actions:

- appoint a project manager

- earmark funds and reserve IT capacity - perform an impact analysis

- draft an internal migration plan

3. Wholesale SCT users will report to the Programme Agency no later than the end of March 2012 when, and with which volume, they are planning to migrate to the SEPA credit transfer in the period until 1 March 2013.

4. Wholesale SCT users will report on the progress of their migration preparations to the Programme Agency at the end of each quarter, using a reporting format drawn up by the Programme Agency. 5. VNO-NCW (employers’ organisation) and MKB-Nederland (SME organisation) will:

• inform their boards and their members of the migration plan once approved by the NFS and the resulting actions for their members by end-March 2012 at the latest;

• discuss the migration plan (after its approval by the NFS) and the resulting actions for their members with their boards no later end-March 2012;

• inform the relevant constituencies of the outcomes of TFSN and NFS meetings during the migration period.

• offer sufficient safeguards that with respect to wholesale SCT users among its constituency, every affiliated industry organisation will:

- inform them of the migration plan and the ensuing actions incumbent upon its members - call upon them to perform such actions.

VNO-NCW and MKB-Nederland will ask affiliated industry organisations to carry out these information actions no later than the end of March 2012.

• organise a platform for Wholesale SCT users aimed at

- learning from each other’s experiences in preparing for the migration,

- answering questions about SEPA migration (with support from the Programme Agency),

- identifying any migration issues faced by multiple wholesale SCT users and communicating these to the Programme Agency.

This platform will start as soon as possible but no later than the end of March 2012 and will consist of electronic information exchange (electronic platform) and at least two (physical) consultation meetings per year.

• distribute SEPA information at least four times a year to the affiliated industry organisations by means of the toolkit that is being developed as part of the SEPA communication campaign, and call upon the affiliated industry organisations to provide SEPA information to their affiliated wholesale SCT users at least four times a year, using the toolkit.

• report no later than the end of March 2012 to the Programme Agency on the safeguards put in place for the implementation of the above action points by industry organisations.

• prior to every TFSN meeting during the migration period, report to the Programme Agency (like all other parties involved) about the progress made on the above action points.

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6. The SEPA Platform for the Public Sector (SPPS) will:

• inform its membership about the NFS-approved migration plan no later than the end of March 2012, and call upon its members to carry out the actions ensuing from the migration plan, taking account of the government’s role model status.

• discuss the migration plan with its members no later than the end of March 2012 and call upon its members to implement the actions ensuing from the migration plan.

• inform its members during the migration period of the outcomes of TFSN and NFS meetings, at least by immediately forwarding the reports of these meetings to its members.

• organise a consultation meeting (at least once a year and more often if desired by its members) of the wholesale SCT users among its constituency with a view to learning from each other’s experiences during the migration preparations, answering questions about the SEPA migration and identifying any migration issues that multiple wholesale SCT users come across and communicating these to the Programme Agency. The first periodic consultation meeting will take place no later than end of March 2012.

• distribute SEPA information at least four times a year to its constituency by means of the toolkit that is being developed as part of the SEPA communication campaign.

• report annually to the Programme Agency, throughout the migration period, about the implementation of the action points in the past year, starting with the report for 2012. The report will be supplied to the Programme Agency by the end of the first quarter at the latest.

Wholesale SCT users mentioned the following migration issues (see also the issue list): • Pipeline effects (issue 21)

3.5 Small-business SCT users Definition

Small-business SCT Users are small to medium-sized businesses/organisations that exclusively use credit transfers for the payments that they initiate. This is a large group of users: according to data collected by DNB as part of the fourth SEPA migration monitor (Autumn 2011), over 60% of the businesses up to 200 employees do not use direct debits. The same applies to over 40% of the businesses between 200 and 1,000 employees. Small-business SCT users occur in all sectors of business and government, or they may be e.g. associations and foundations.

The SEPA migration monitor reveals that many larger small-business SCT users (20 or more employees) use standard software packages to process their payments. A small number use a customised package (as do wholesale SCT users). Many businesses with fewer than 20 employees do not use a software package but process their payments via internet banking.

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Milestones

The most important milestones in the migration of small-business SCT users are:

1. Product specifications for the basic product range have been finalised (for some smaller banks the finalisation deadline is 1 April 2012).

2. Software suppliers of small-business SCT users ensure that their software packages are ready for using the basic product range no later than 1 October 2012.

3. Until 1 March 2013, early movers may migrate in consultation with their bank.

4. The infrastructure for the mass migration of small-business SCT users is ready no later than 1 March 2013.

5. The mass migration of small-business SCT users takes place in the period from 1 March 2013 to 1 February 2014.

The basic product range for small-business SCT users consists of: • Internet-based SEPA credit transfer (B2B)

• Batch delivery of payment orders by businesses (XML) • Reporting (accountability) to businesses (XML/MT940)

The basic product range and other infrastructure will be ready for early movers before 1 March 2013. The infrastructure is ready for the mass migration of small-business SCT users no later than 1 March 2013. The main difference with wholesale SCT users concerns the mass processing and related processes and procedures for delivery and reporting. These will be more standardised for small-business SCT users. The basic product range for small-business SCT users that do not use a software package also includes: • SEPA standing order

Note:

• This product will be available prior to the mass migration of small-business SCT users. The additional product range consists of:

• Urgent payment

Banks and software suppliers offer support

During the migration to SEPA payment products small-business SCT users are supported by their bank and (if applicable) their software supplier, both in the preparation phase and during the migration period. Small-business SCT users can use the IBAN BIC Service to convert their bank account files. Software suppliers can provide additional support. Banks and (if applicable) software suppliers also provide support with the technical changes (the switch to XML, insofar as batch payments are used) and the changes in the reporting processes.

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Action points

1. Small-business SCT users will migrate to the use of the basic product range for the SEPA credit transfer no later than 1 February 2014.

2. At their bank’s request small-business SCT users will communicate to their bank when, and with what volume, they will migrate to the SEPA credit transfer.

3. MKB-Nederland and VNO-NCW will:

• inform their members of the outcomes of TFSN and NFS meetings during the migration period. • offer sufficient safeguards that every affiliated industry organisation with small-business SCT users

among its members will:

- inform them of the migration plan and the ensuing actions incumbent upon its members - call upon them to perform such actions.

MKB-Nederland and VNO-NCW will ask the affiliated industry organisations to carry out these information actions no later than the end of March 2012.

• organise a platform for affiliated industry organisations with small-business SCT users among their members aimed at

- learning from each other’s experiences in preparing for migration,

- answering questions about SEPA migration (with support from the Programme Agency), - identifying any migration issues faced by multiple small-business SCT users and communicating

these to the Programme Agency.

This platform will start as soon as possible but no later than the end of March 2012 and will consist of electronic information exchange (electronic platform) and at least two (physical) consultation meetings per year.

• call upon affiliated industry organisations to take part in consultation meetings about the SEPA migration for industry organisations, organised by VNO-NCW and MKB-Nederland in cooperation with the Programme Agency, at least twice a year.

• call upon affiliated industry organisations to devote attention to the SEPA migration for industry organisations in at least two consultation meetings per year during the migration period, and to accept the Programme Agency’s offer to contribute to these consultation meetings (presentations, answering questions).

• distribute SEPA information at least four times a year to the affiliated industry organisations by means of the toolkit that is being developed as part of the SEPA communication campaign, and call upon the affiliated industry organisations to provide SEPA information to their affiliated small business SCT users at least four times a year, using the toolkit.

• report no later than the end of March 2012 to the Programme Agency on the safeguards that have been put in place for the implementation of the above action points.

• report annually, prior to every TFSN meeting during the migration period, to the Programme Agency (like all other parties involved) about the progress made on the above action points.

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4. The SPPS will:

• inform its constituency about the NFS-approved migration plan no later than the end of March 2012, and call upon its members to carry out the actions ensuing from the migration plan, taking account of the government’s role model status.

• discuss the migration plan with its members no later than the end of March 2012 and call upon its constituency to implement the actions ensuing from the migration plan.

• organise a consultation meeting (at least once a year and more often if desired by its members) of the small-business SCT users among its members with a view to learning from each other’s experiences during the migration preparations, answering questions about the SEPA migration and identifying any migration issues that multiple small-business SCT users come across and communicating these to the Programme Agency. The first periodic consultation meeting will take place no later than end of March 2012.

• distribute SEPA information at least four times a year to its members by means of the toolkit that is being developed as part of the SEPA communication campaign.

5. The Dutch Association of Municipalities (VNG) will:

• inform its membership about the NFS-approved migration plan no later than the end of March 2012, and call upon its constituency to carry out the actions ensuing from the migration plan, taking account of the government’s role model status.

• discuss the migration plan with its members no later than the end of March 2012 and call upon its constituency to implement the actions ensuing from the migration plan.

• inform its members during the migration period of the relevant outcomes of TFSN and NFS meetings as soon as possible after the reports of these meetings have been distributed.

• organise consultation meetings (at least twice a year) between the small-business SCT users among its members with a view to learning from each other’s experiences during the migration preparations, answering questions about the SEPA migration and identifying any migration issues that multiple small-business SCT users come across and communicating these to the Programme Agency. The first periodic consultation meeting will take place no later than end of March 2012.

• distribute SEPA information at least four times a year to its constituency by means of the toolkit that is being developed as part of the SEPA communication campaign.

Small-business SCT users mentioned the following migration issues (see also the issue list): • Pipeline effects (issue 21)

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3.6 Wholesale SDD billers Definition

Billers are business users that make use of direct debit, Acceptgiro (giro collection forms), digital invoice and/or iDEAL for the payments that they initiate. Wholesale SDD billers belong to the group of about 50 billers that each initiate more than 4.5 million direct debit transactions per year. Wholesale SDD billers together account for 50% of the Dutch direct debit volume (in all, there are about 140,000 billers in the Netherlands). Wholesale SDD billers are found in various sectors, including the public sector, financial services, utilities, telecommunication and lotteries.

Milestones

The most important milestones in the migration of SDD billers are:

2. Software suppliers of Wholesale SDD billers ensure that their software packages are ready for using the basic product range no later than 1 October 2012.

3. Until 1 January 2013, early movers may migrate in consultation with their bank.

4. The infrastructure for the mass migration of Wholesale SDD billers is ready no later than 1 January 2013. 5. The mass migration of Wholesale SDD billers will take place in the period from 1 January 2013 to

1 July 2013. Note:

• Billers can opt to migrate to the SEPA credit transfer first, before switching to the SEPA direct debit. Availability of basic and additional product ranges

The basic product range consists of: • Internet-based SEPA credit transfer (B2B) • SEPA direct debit

• Batch delivery by businesses of B2B payment and direct debit orders (XML) • Reporting (accountability) to businesses (XML/MT940)

The basic product range and other infrastructure must be ready for early movers before 1 January 2013. The infrastructure is ready for mass migration no later than 1 January 2013. It should be noted that existing mandates are also valid for the SEPA direct debit. Billers are only required to request a new mandate and debtors are only required to issue a new mandate for the B2B SEPA direct debit

The additional product range consists of: • Urgent payment • B2B SEPA direct debit • E-Mandates: SEPA direct debit with mandate via the internet • iDEAL • Digital invoice • (possibly) Non-refundable direct debit: SEPA direct debit without right of refund • (possibly) Acceptgiro (giro collection form)

Gradual migration, pilot and testing

SDD is a complex product whose migration must be carefully prepared. Without careful preparation there is the risk that a relatively large number of direct debit instructions cannot be processed in one go. Testing, a pilot and a gradual migration are necessary to mitigate these risks.

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Banks and software suppliers provide support

During the migration to SEPA payment products, wholesale SDD billers will work closely with their bank and software supplier, both in the preparation phase and during the migration period. Where necessary, banks and software suppliers will offer customised support. Wholesale SDD billers can use the IBAN BIC Service to convert their bank account files. The technical changes (the switch to XML) and the changes in the reporting process will be introduced together with the bank and the software supplier.

Action points

1. Wholesale SDD billers will migrate to the use of the basic product range for the SEPA credit transfer and the SEPA direct debit in the period until 1 July 2013.

2. Wholesale SDD billers that are yet to start preparing for the SEPA migration will perform at least the following actions:

- appoint a project manager

- earmark funds and reserve IT capacity - perform an impact analysis

- draft an internal migration plan

3. Wholesale SDD billers will report to the Programme Agency no later than the end of March 2012 when, and with which volume, they are planning to migrate to the SEPA credit transfer and the SEPA direct debit.

4. Wholesale SDD billers will report on the progress of their migration preparations to the Programme Agency at the end of each quarter, using a reporting format drawn up by the Programme Agency. 5. VNO-NCW and MKB-Nederland will:

• inform the affiliated industry organisations of the outcomes of TFSN and NFS meetings during the migration period.

• offer sufficient safeguards that every affiliated industry organisation with wholesale SDD billers among its members will:

- inform them of the migration plan and the ensuing actions incumbent upon its members - call upon the wholesale SDD billers among its members to implement these actions.

VNO-NCW and MKB-Nederland will ask affiliated industry organisations to carry out these information actions no later than the end of March 2012.

• organise a platform for wholesale SDD billers aimed at:

- answering questions about the SEPA migration (with support from the Programme Agency),

- identifying any migration issues that multiple wholesale SDD billers come across and communicating these to the Programme Agency.

This platform will start as soon as possible but no later than the end of March 2012 and will consist of electronic information exchange (electronic platform) and at least two (actual) consultation meetings per year. • distribute SEPA information at least four times a year to the affiliated industry organisations by means

of the toolkit that is being developed as part of the SEPA communication campaign, and call upon the affiliated industry organisations to provide SEPA information to their affiliated wholesale SDD billers at least four times a year, using the toolkit.

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• report no later than the end of March 2012 to the Programme Agency on the safeguards put in place for the implementation of the above action points by industry organisations.

Prior to every TFSN meeting during the migration period, report to the Programme Agency (like all other parties involved) about the progress made on the above action points.

6. The SPPS will:

• inform its constituency about the NFS-approved migration plan no later than the end of March 2012, and call upon its constituency to carry out the actions ensuing from the migration plan, taking account of the government’s role model status.

• discuss the migration plan with its constituency no later than the end of March 2012 and call upon its constituency to implement the actions ensuing from the migration plan.

• organise a consultation meeting (at least once a year and more often if desired by its members) of the wholesale SDD billers among its members with a view to learning from each other’s experiences during the migration preparations, answering questions about the SEPA migration and identifying any migration issues that multiple wholesale SDD billers come across and communicating these to the Programme Agency. The first periodic consultation meeting will take place no later than end of March 2012.

The wholesale SDD billers mentioned the following migration issues (see also the issue list): • Lack of clarity about the processing of payments in the dual period (issue 1) • Absence of specifications for the additional product range (issue 3) • Possible reputation damage and extra costs for early movers (issue 4) • Lack of clarity about Acceptgiro (issue 8) • Doubts about whether banks will be sufficiently prepared for the processing of large volumes of payment instructions (issue 11) • Unclear aspects of SDD (issue 13) • Unclear aspects regarding the use of BIC (issue 16) • Lack of clarity about the regulation of micro-businesses (issue 19) • Pipeline effects (issue 21)

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3.7 Small-business SDD billers Definition

Incassanten zijn zakelijke gebruikers van incasso, Acceptgiro, digitale nota en/of iDEAL voor hun inkomend Billers are business users of direct debit, Acceptgiro, digital invoice and/or iDEAL for their incoming payments. The roughly 140,000 small business SDD billers together account for some 50% of the direct debit volume. Small-business SDD billers are found in a large number of different sectors, including: financial services, public bodies, associations and fund-raising organisations.

Milestones

The most important milestones in the migration of small-business SDD billers are:

2. Software suppliers of small-business SDD billers ensure that their software packages are ready for using the basic product range no later than 1 October 2012.

3. Until 1 July 2013, early movers may migrate in consultation with their bank.

4. The infrastructure for the mass migration of small-business SDD billers is ready no later than 1 July 2013. 5. The mass migration of small-business SDD billers will take place in the period from 1 July 2013 to

1 February 2014. Note:

• Billers can opt to migrate to the SEPA credit transfer first, before switching to the SEPA direct debit. Availability of basic and additional product ranges

As with the Large SDD billers, the basic product range consists of: • Internet-based SEPA credit transfer (B2B)

• SEPA direct debit

• Batch delivery by businesses of B2B payment and direct debit orders (XML) • Reporting (accountability) to businesses (XML/MT940)

The basic product range and other infrastructure must be ready for early movers before 1 January 2013. The infrastructure is ready for mass migration no later than 1 January 2013. The main difference with wholesale SDD billers concerns the mass processing and related delivery and reporting processes and procedures. These will be more standardised for small-business SDD billers. It should be noted that existing mandates are also valid for the SEPA direct debit. Billers are only required to request a new mandate and debtors are only required to issue a new mandate for the B2B SEPA direct debit

For small-business SDD billers who do not use a software package, the basic product range also includes the: • SEPA standing order

Note:

• This product will be available before the mass migration of small-business SDD billers. As with wholesale SDD billers, the additional product range consists of:

• Urgent payment • B2B SEPA direct debit • E-Mandates: SEPA direct debit with mandate via the internet • iDEAL • Digital invoice • (possibly) Non-refundable direct debit: SEPA direct debit without right of refund • (possibly) Acceptgiro (giro collection form)

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Gradual migration, pilot and testing

SDD is a complex product whose migration must be carefully prepared. Without careful preparation there is the risk that a relatively large number of direct debit instructions cannot be processed in one go. Testing, a pilot and a gradual migration are necessary to mitigate these risks.

Banks and software suppliers provide support

Small-business SDD billers can also use the IBAN BIC Service to convert their customers’ bank account files. Together with their bank and software supplier, they can plan the technical changes (the switch to XML) and the changes to the reporting process. In line with the current support for payments, banks and software suppliers will provide information via websites, brochures and, if necessary, a help desk or other form of personal support during the preparation for the migration to SEPA. New contracts and new arrangements will need to be made specifically for direct debits that involve more operational changes. A step-by-step plan for the switch to the SEPA direct debit is posted on www.sepanl.nl.

Action points

1. Small-business SDD billers will migrate to the use of the basic product range for the SEPA credit transfer and the SEPA direct debit no later than 1 February 2014.

2. At their bank’s request, Small-business SDD billers will inform their bank when, and with which volume, they will migrate to the SEPA credit transfer.

3. MKB-Nederland and VNO-NCW will:

• inform the affiliated industry organisations of the outcomes of TFSN and NFS meetings during the migration period;

• offer sufficient safeguards that every affiliated industry organisation with small-business SDD billers among its members will:

- inform them of the migration plan and the ensuing actions incumbent upon its members - call upon the small-business SDD billers among its members to implement these actions. MKB-Nederland and VNO-NCW will ask the affiliated industry organisations to carry out these information actions no later than the end of March 2012.

• organise a platform for affiliated industry organisations with small-business SDD billers among their members aimed at:

- answering questions about SEPA migration (with support from the Programme Agency)

- identifying any migration issues that multiple small business SDD billers face and communicating these to the Programme Agency.

This platform will start as soon as possible but no later than the end of March 2012 and will consist of electronic information exchange (electronic platform) and at least two (actual) consultation meetings per year.

• call upon affiliated industry organisations to take part in consultation meetings about the SEPA migration for industry organisations, organised by VNO-NCW and MKB-Nederland in cooperation with the Programme Agency, at least twice a year.

• call upon affiliated industry organisations to devote attention to the SEPA migration for industry organisations in at least two consultation meetings per year during the migration period, and to accept the Programme Agency’s offer to contribute to these consultation meetings (presentations, answering questions).

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• distribute SEPA information at least four times a year to the affiliated industry organisations by means of the toolkit that is being developed as part of the SEPA communication campaign, and call upon the affiliated industry organisations to provide SEPA information to their affiliated small-business SDD billers at least four times a year, using the toolkit.

• report no later than the end of March 2012 to the Programme Agency on the safeguards that have been put in place for the implementation of the above action points.

• report annually, prior to every TFSN meeting during the migration period, to the Programme Agency (like all other parties involved) about the progress made on the above action points.

4. The SPPS will:

• inform its constituency about the NFS-approved migration plan no later than the end of March 2011, and call upon its constituency to carry out the actions ensuing from the migration plan, taking account of the government’s role model status.

• organise a consultation meeting (at least once a year and more often if desired by its members) of the small business SDD billers among its members with a view to learning from each other’s experiences during the migration preparations, answering questions about the SEPA migration and identifying any migration issues that multiple small-business SDD billers come across and communicating these to the Programme Agency. The first periodic consultation meeting will take place no later than end of March 2012.

5. The VNG will:

• inform its membership about the NFS-approved migration plan no later than the end of March 2012, and call upon its members to carry out the actions ensuing from the migration plan, taking account of the government’s role model status.

• inform its constituency of the relevant outcomes of TFSN and NFS meetings during the migration period, as soon as possible after the reports of these meetings have been distributed.

• organise a consultation meeting (at least twice a year) of the small business SDD billers among its consti-tuency with a view to learning from each other’s experiences during the migration preparations, answering questions about the SEPA migration and identifying any migration issues that multiple small business SDD billers come across and communicating these to the Programme Agency. The first periodic consultation meeting will take place no later than end of March 2012.

Small-business SDD billers mentioned the following migration issues (see also the issue list): • Pipeline effects (issue 21)

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3.8 Consumers Definition

Consumers are the retail customers of banks. All inhabitants of the Netherlands with a bank account belong to this group.

Milestones

The most important milestones in the migration of consumers are: 1. The basic product range is already available at most banks.

2. During the migration period consumers will increasingly be requested by creditors to transfer money to the creditor’s international bank account number and to fill in their own IBAN on direct debit mandates and to communicate their IBAN to individuals / organisations from whom they receive money.

3. The SEPA credit transfer will be the preferred option in the internet banking environment no later than 1 April 2013. The timing can vary between banks. The alternative option of using BBAN-based payments remains available until the end of the migration period.

4. Paper credit transfer forms will remain available until no later than 1 April 2013. The timing may vary between banks. Not all banks will include paper credit transfer forms in their product range. The alternative option of using the old Dutch credit transfer forms remains available until the end of the migration period.

The basic product range for consumers consists of: • Internet-based SEPA credit transfer

• paper-based SEPA credit transfer • SEPA standing order

Note:

• The Internet-based SEPA credit transfer is already available from most banks. The Internet-based standing order will not be available beyond 1 October 2012. The paper-based SCT will not be available beyond 1 April 2013.

The additional product range consists of: • Urgent payment

• SEPA credit transfer by telephone

Creditors can enable consumers to pay with: • Paper-based SEPA direct debit mandate • Internet SEPA direct debit mandate (e-Mandate) • iDEAL • Digital invoice • (possibly) Acceptgiro (giro collection form) • (possibly) Gaming direct debit: SEPA direct debit without right of refund Note: • Mandates for SEPA direct debits can already be issued.

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Banks offer support

Consumers make use of both online and paper-based banking products for transferring funds. In the course of the migration, they will increasingly be confronted with large business users who have already transferred to SEPA products and therefore already state their IBAN instead of their current Dutch account number or ask for the consumer’s IBAN on direct debit mandates. Consumers will therefore increasingly use the IBAN. They can count on support from their bank in this connection. Consumers make the vast majority of their credit transfers (more than 90%) in their internet banking environment. The banks will automatically add the IBANs to the address books in the internet banking environment. The IBAN BIC Service can be used to look up account numbers that are not in the address books and for paper-based transfers. Existing mandates for the (generally recurrent) Dutch direct debits will be automatically converted to mandates for the SEPA direct debit. The creditor will only ask the consumer to fill in his IBAN for

new mandates. Consumers can already find their own IBAN on bank statements, in the internet banking environment and via the IBAN BIC Service. During the migration period, more and more consumers will receive a bank card with their IBAN on it.

Consumers with an impairment

The migration to the SEPA payment products also has consequences for consumers with an impairment. Banks and umbrella organisations are looking for suitable solutions to accessibility problems.

Action points for consumers

1. Deliver payment instructions with IBAN, at a creditor’s request (via the internet and credit transfer forms), throughout the migration period.

2. Communicate your own IBAN on request to persons / organisations from which money is received throughout the migration period.

3. In the case of new mandates, fill in your own IBAN at the creditor’s request, throughout the migration period.

4. Consumers’ organisations Consumentenbond, Viziris, CG-Raad and ANBO will:

• distribute SEPA information at least twice a year to their members by means of he toolkit that is being developed as part of the SEPA communication campaign, throughout the communication campaign for private individuals.

• communicate any migration issues to the Programme Agency during the migration period; • look together with banks for solutions to any accessibility problems. During the migration period,

they will communicate identified accessibility problems to the Programme Agency. Note:

• Consumers will not switch over at once to SEPA payment instruments, but will increasingly use these during the migration period. The full migration to the basic product range will only be completed on the end date for national payment instruments, 1 February 2014.

The following migration issues were mentioned by consumer organisations (see also the issue list): • Lack of clarity about e-Mandates (issue 3) • Transition period for consumers (issue 5) • Accessibility of SEPA products (issue 7) • Lack of clarity about Acceptgiro (issue 8) • Importance of good communication (issue 9) • Pipeline effects (issue 21)

NATIONAL SEPA MIGRATION PLAN. 17 th February 2012

NATIONAL SEPA

MIGRATION PLAN

TABLE OF CONTENTS

PREFACE

CHAPTER 3

MIGRATION SCENARIO PROPOSAL