Leapcard not taking Non-Irish Bank accounts for Auto Top Up Feature by Direct Debit

• Complaints to the National Transport Authority (unsuccessfully see below)
  
  
• Complaints to The Competition and Consumer Protection Commission (CCPC) which takes the complaint but does not deal with individual complaints nor will it provide an outcome back to individual
  
  
• Complaints via SOLVIT (an EU forum that deals with breaches of EU rules by Government bodies) currently waiting for the Irish Department of Enterprise to provide feedback to the relevant authorities. The French & German SOLVIT services are involved but the Irish SOLVIT so far has not responded despite being out of the agreed time frames.
  
  
• Complaints to the responsible Directorate in the European Commission (Financial Stability, Financial Services and Capital Markets Union)

Many thanks for your query and apologies for the delay in response. I wanted to ensure that NTA provided a comprehensive answer to your query.

It is the case that while we at all times endeavour to comply with the rules governing the areas in which we operate, there are significant technical challenges that are preventing NTA from complying with specific SEPA rules at this time. I also wish to put this answer in the context of our obligations under the legislation which governs the NTA, and in particular one of our core objectives which is to provide value for money. With this in mind when you had previously contacted us regarding the issue of allowing Direct Debits from non Irish Bank accounts, the matter had been at that point under investigation and consideration for some time and we had hoped to have a more positive answer.

Unfortunately, following consultation with our solution architects and providers we discovered that, as our back-office systems were built some time ago (prior to SEPA), there are existing technical restrictions in our systems which cannot easily accommodate IBANs. Although we have been able to implement a workaround for Irish bank account numbers (by performing a reverse lookup and conversion process on the inputs and outputs) to allow Irish account holders to use their IBAN to sign up for Auto top-up, we cannot use this process for non-Irish IBANs. As a result we have investigated alternative solutions as well as separately investigated converting the entire system to use IBANs. However, to date we have not received a proposal which could satisfy technical, security and financial integrity prerequisites and provide value for money. In fact, the cost for implementing partial solutions was so high as to be prohibitive. Consequently our focus has turned to a complete end-to-end solution. This would require a complete system rebuild and an extensive testing phase, the total cost of which would be substantial. When viewed in light of the very small percentage of customers that it would service, we do not believe that it would be a prudent use of taxpayers’ funds as a standalone development.

Instead as an alternative to auto top-up NTA is providing a mobile phone solution (the Leap Top-Up app) which can be accessed anywhere in the world and can instantaneously reload a Leap card as well as display the recent travel history, balance and ticket information. It works with any Android (v4.4 or later) phone that has NFC. NTA is also hopeful that Apple will allow access to the NFC chip on the latest iPhones in the near future. The growth in use that we have experienced on the Leap top-up app since its launch in January 2016 clearly indicates that there is a greater appetite for an on-demand reload capability that far exceeds the demand for auto top-up. Therefore it is likely that NTA will focus its limited resources in this area until such time as we have the funding to develop the next iteration of the Leap card systems to include the SEPA requirements (likely in conjunction with a number of other enhancements).

To be clear, it is our intention that a new iteration of our back office systems will comply with the SEPA requirements. However, in the absence of confirmed funding NTA cannot define any timeline for this to complete. I appreciate that this is not the answer that you are looking for, but it is simply the case that since we have an alternative available (the Leap Top-Up app), and given the significant technical challenges necessitating a substantial financial investment, whilst there is limited demand for such auto top-ups, we have to make the most efficient use of our available resources.

Thank you for your email to the Competition and Consumer Protection Commission (CCPC) in relation to topping up your leap card via direct debit.

The aim of the Single European Payments Area (SEPA) is to standardise the transfer of electronic payments, for example direct debits and standing orders, across Europe. This means that the cost and process for making payments to any SEPA country is the same as making a payment in Ireland.

The CCPC is the competent authority for the purposes of enforcing Article 9(1) and 9(2) of the SEPA Regulations. Article 9(2) provides that a trader accepting a credit transfer or using a direct debit to collect funds from a consumer holding a payment account located within the Union shall not specify the Member State in which that payment account is to be located, provided that the payment account is in another Member State

We note that you have tried to resolve the issue with the National Transport Authority. We would appreciate if you could send us any additional relevant information, if any, that is available to you on the issue i.e. any further written correspondence between yourself and the National Transport Authority.

We will provide the information to our Consumer Enforcement Division (CED) for information. Our CED examine consumer issues in the context of overall consumer detriment, or loss, and carry out whatever action (if any) is deemed necessary and appropriate. The CCPC is grateful to consumers who take the time to make complaints and highlight areas where there might be detriment however we are not in a position to investigate all complaints. You should also be aware that due to the volume of complaints we receive, it is not possible for us to respond to individual complainants regarding the outcome of analysis of their complaint. We will of course contact consumers if the need arises either in the course of or on completion of an examination.

In the event that CED deem it necessary to contact the relevant body, it is possible that your identity may become apparent to the National Transport Authority in light of your communication. Please also advice whether or not it is acceptable to you that your identity is confirmed in order to resolve the issue if actioned by the CED.

We hope you have found this information useful and if you have any further consumer related queries please do not hesitate to contact us on 1890 432 432 or (01) 4025555.