CESOP correction

The obligation for payment service providers (PSPs) to submit CESOP reports is unusual in many respects. This article sheds light on the topic of "CESOP correction", i.e. when the CESOP system rejects a report for post-processing.

In a first step, the reports submitted by (German) payment service providers are validated by the German tax administration in accordance with the minimum requirements set out in EU Commission Implementing Regulation 2022/1504, among others.

If the validation is positive, the verified report is forwarded to CESOP at EU level, where it is validated again based on all applicable rules implemented in the XSD and in additional technical and business rules. A positive validation of a declaration transmitted by the PSPs will only be returned by the BZSt to the PSP after transmission to CESOP at EU level and receipt of a corresponding positive validation result.

A negative validation result is transmitted to the PSP in XSD format. The XML file contains a "ValidationResult" instead of the "PaymentDataBody" and the "MessageSpec" contains a "CorrMessageRefID", which refers to the message to be corrected (it refers to the original "MessageRefID").

The CESOP correction

If a CESOP message is rejected, this is either for technical reasons (file cannot be decrypted, is too large, contains viruses, etc.) or logical reasons (BIC incorrect, transaction not in the reporting period, "TransactionIdentifier" used several times, etc.). A sophisticated CESOP reporting system will of course carry out appropriate checks before transmission so that no "rejects" are to be expected and therefore no corrections need to be made.

Nevertheless, a good CESOP system must monitor the receipt of reject messages and react accordingly, because the correction must be made - otherwise the message is deemed not to have been submitted. The correction mechanism does not include the transmission of new data, i.e. if new data is to be "added", this must be done in a separate message and must not be "packed" into a correction.

Deletion of data

One form of CESOP correction is the deletion of data or reports. The process of deleting a previously submitted report by the PSP does not initially appear to be relevant, according to the motto "it is better to report too much than too little". However, the guidelines on CESOP notifications explicitly state that the transmission of data below the threshold may be considered a breach of the provisions of Article 243b and that sanctions may be imposed on the PSP.
It is therefore highly advisable to make the CESOP notifications carefully.

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