The challenge
CESOP — the EU's Central Electronic System of Payment information — introduced a new class of obligation for payment service providers from April 2024: systematic identification and reporting of cross-border payment activity to support VAT fraud prevention across the bloc. For a European PSP operating across multiple jurisdictions, this was a non-trivial compliance programme with a hard deadline.
The client came to us in 2023 with both a regulatory challenge and a data challenge. The requirements were still evolving, the affected transaction volumes were high, and the underlying payment and merchant data was fragmented across operational systems. The organisation needed both strategic guidance to interpret the regulation and hands-on technical delivery to build a solution in time.
The stakes were straightforward: meet the April 2024 deadline or face regulatory exposure.
Our approach
We embedded alongside the client's compliance, operations, and technology teams and ran a structured engagement across four phases: regulatory analysis, solution design, implementation, and operational readiness. The goal was never just to build a system — it was to make sure the organisation understood what it was building and why, so the solution would hold up under scrutiny.
Outcomes
The client achieved full CESOP reporting readiness ahead of the April 2024 enforcement date — no last-minute scramble, no manual workarounds, and no regulatory exposure at go-live.
- Compliant reporting delivered on time — automated generation of regulatory submissions for central and regional EU authorities
- Eliminated manual intervention — rule-based transaction identification and automated output replaced error-prone manual processes
- Improved data governance — the programme surfaced and resolved data quality issues that pre-dated the CESOP requirement
- Full auditability — every reported transaction is traceable back through the data pipeline with a clear audit trail
- Future-proof architecture — the reporting framework is designed to absorb regulatory updates without requiring a rebuild
- Stronger reporting capability overall — the client left the engagement with materially better visibility across its payments data
Why this matters
Regulatory deadlines are unforgiving. The cost of a missed CESOP submission isn't just a fine — it's reputational risk, regulatory scrutiny, and the prospect of emergency remediation work under pressure. Getting ahead of the deadline with a well-designed, auditable solution is the only sensible approach, and that requires both regulatory understanding and technical execution working together from the start.
This engagement demonstrated our ability to operate at the intersection of compliance and technology — interpreting evolving regulatory requirements, designing data-intensive solutions, and delivering them on time within a regulated environment.