North Macedonia’s formal accession to the Single Euro Payments Area (“SEPA”) marks a significant step toward deeper European financial integration. Following the European Payments Council’s (“EPC”) decision in early 2025 to extend SEPA’s geographical scope to include the Republic of North Macedonia, commercial banks and other payment service providers (“PSPs”) based in the country are now eligible to join the SEPA Credit Transfer (“SCT”) scheme. This milestone will enable citizens and businesses in the Republic of North Macedonia to send and receive euro payments under the same efficient and standardized conditions enjoyed across the SEPA area.
However, SEPA membership for commercial banks and other PSPs is not automatic. Each institution must individually complete a specific adherence process managed by the EPC. In particular, applicants i.e. national commercial banks and other PSP’s must demonstrate compliance with the SEPA Credit Transfer Rulebook, technical operational standards, and crucially, full legal and regulatory alignment. The EPC requires each PSP to submit a comprehensive adherence package, which includes the necessary contractual and procedural documentation outlined in the SEPA Credit Transfer Scheme Adherence Pack, as well as a formal legal opinion verifying that the applicant meets the eligibility criteria and that the legal framework governing its operations is consistent with SEPA rules.
The legal opinion is a critical component of the application and must follow the structure set by the EPC’s official standard. It must confirm, among other things, that the PSP is properly licensed under national law, that no legal impediments exist for offering SEPA Credit Transfer services, and that the PSP possesses the necessary legal capacity to enter into binding obligations under the SEPA framework. Furthermore, the legal opinion must thoroughly assess the compatibility of domestic laws with the SEPA Credit Transfer Scheme provisions, particularly regarding payment execution standards, customer rights, and anti-money laundering compliance. Importantly, this legal opinion must be formally addressed and delivered to the European Payments Council AISBL at its official seat in Brussels, Belgium. It must be signed by qualified legal counsel, adhering to the specific format required by the EPC, and it is intended to be relied upon by the EPC and its legal advisors as part of the eligibility verification process.
Drafting a SEPA-compliant legal opinion requires specialized expertise in both domestic financial regulation and SEPA scheme requirements. Legal counsel must have a thorough understanding of the applicant’s organizational structure, licensing status, and operational arrangements. They must also be familiar with the EPC’s standard templates and the specific legal issues addressed in the SEPA Rulebook. Key challenges in drafting the legal opinion include ensuring consistency and alignment between national laws and SEPA requirements, especially in areas such as anti-money laundering, data protection, and consumer rights, coordinating with multiple stakeholders, including regulatory authorities, internal compliance teams, and external advisors and addressing unique circumstances, such as group structures, subsidiaries, or cross-border operations.
SEPA membership is expected to yield substantial benefits for North Macedonia, including reduced payment costs, accelerated financial sector digitalization, enhanced economic integration with the EU, and increased international credibility. The successful integration of North Macedonia’s financial institutions into SEPA will depend on continued alignment with EU regulations, investment in compliance and operational capacity, and effective stakeholder coordination. Legal advisors and compliance professionals will play a vital role in supporting this transition, ensuring that North Macedonian PSPs meet the highest standards of legal and regulatory compliance. As SEPA continues to expand and evolve, North Macedonia’s experience offers valuable insights and best practices for other countries seeking to join the European payments community.
By Gjorgji Georgievski, Partner, and Boban Velickovic, Senior Associate, ODI Law
