The German Federal Financial Supervisory Authority (BaFin) has imposed fines totaling €26,000 on Vivid Money S.A.

The Luxembourg-based firm failed for an extended period to report its account models offered to consumers in Germany to the BaFin account comparison service. Furthermore, it violated its supervisory duties regarding internal processes for publishing information.

These procedural weaknesses resulted in the firm not fully providing fee information and a glossary on its website for a considerable time.

The BaFin account comparison service provides consumers with the necessary transparency to make an initial assessment when searching for a current account. It contains information on account models from approximately 1,100 payment service providers, encompassing a total of 6,600 payment account tariffs. The account models are presented based on comparison criteria such as monthly fees and overdraft interest rates.

Under the Payment Accounts Act (ZKG), providers of payment accounts – including current and basic accounts – are obligated to provide BaFin with the information necessary for account comparison.

Account providers must report new account models or changes to comparison criteria for existing offers to BaFin’s account comparison tool within three business days.

According to the Comparison Website Reporting Ordinance (VglWebMV), reporting must be submitted via BaFin’s reporting and publication platform (MVP portal). This digital interface is designed to enable automated reporting. After reporting, the data is transferred to the account comparison tool without further review or processing by BaFin. However, BaFin conducts random quality checks.

According to Section 5, Paragraph 3 of the German Ordinance on Fees and Charges (VglWebMV), payment service providers must comply with the information and guidance published by BaFin (for example, documentation on generating payment account reports in XML format, FAQs).

Furthermore, under the German Payment Accounts Act (ZKG), payment service providers are obligated to make a current version of the fee information readily available to consumers at all times and, if applicable, to publish it on their website.

The fee information aims to increase the transparency and comparability of fees associated with payment accounts. It includes at least the list of the most representative services associated with a payment account, as defined by BaFin pursuant to Section 47 of the ZKG, as well as any associated contractual penalties, and presents this information in a standardized format. Payment service providers can use BaFin’s template for this purpose.

In addition, a clearly and comprehensibly written glossary of services associated with a payment account must be published. BaFin also provides a template for this.

The standardized payment account terminology serves to improve the comprehensibility and comparability of fees for consumers. Therefore, the standardized terms defined in Delegated Regulation (EU) 2018/32 must be used in both fee information and all other information provided to consumers.

If payment service providers fail to comply with these reporting or publication obligations, or fail to comply correctly, completely, or on time, BaFin may impose a fine.