Seven Banks Merged Away. SEPA Still Lists Them as Live.

VR Bank Fulda eG, PSD Bank Hannover eG, Volksbank Düsseldorf Neuss eG and four others have had their Legal Entity Identifiers retired. In each case the global register that issues those identifiers now records the entity as inactive and names the entity that absorbed it, and in each case that record was last updated within the past four weeks.

All seven are still listed as live participants in SEPA Credit Transfer and SEPA Instant, under their own names and their own BICs.

Two registers, one join

The European Payments Council publishes the full membership of each SEPA scheme as a downloadable file, with a BIC for every participant. The Global Legal Entity Identifier Foundation publishes the world's LEI register, 3,459,313 records, and maps each one to the BICs it covers.

Join the two on BIC and you can ask a question neither body answers on its own: of the institutions Europe lists as able to move euros, how many are in good standing in the register that is supposed to say who they legally are?

Of 3,504 active credit transfer participants, 3,237 resolve to an LEI — 92.4%. Those resolve to 3,220 distinct identifiers, because one LEI can carry dozens of BICs. On the instant side the match rate is 92.8%.

Among the 3,220: 3,171 are issued and current, 41 are lapsed, 7 are retired, and one is mid-transfer between the organisations that maintain it.

The seven

A retired LEI with an inactive entity status and a named successor is how GLEIF records a legal entity that has been absorbed into another. All seven of these carry exactly one successor.

Six are German cooperative or PSD banks and one is Austrian. Their GLEIF records were updated between 21 September and 9 October 2026 — every one of them inside the four weeks before these registers were read.

And every one of the seven is listed as an active participant in both SEPA schemes, not just the credit transfer one.

There is an eighth worth noting. VR Bank EifelLand eG is in pending transfer, with its entity status still active, no successor recorded and a renewal falling due on 15 October 2026 — two days after this reading.

Eleven years overdue, still listed

Forty-one of the LEIs attached to SEPA participants are lapsed, meaning the holder has not revalidated its reference data by the renewal date. Twenty-seven of those also attach to instant scheme participants.

The median is 428 days past due. Twenty-five are more than a year overdue, fifteen more than two years, eight more than five.

The longest is TC Ziraat Bankasi AS, registered in Greece. Its renewal fell due on 5 November 2015. That is 3,995 days ago. The record was last touched in October 2019. The entity is active and so is its SEPA membership.

A lapse is not a failure. It means nobody has confirmed, to the body whose job is confirming it, that the name, address and legal form on file are still correct.

The fourteen nobody could check

GLEIF marks each record with how far its data was corroborated. Across the 3,220, 3,175 are fully corroborated against a business register, 31 partially, and 14 are entity-supplied only — the entity said so and nothing independent confirmed it.

Eight of those fourteen are central banks or sovereign states: the Bundesbank, the Bank of Greece, the Bulgarian National Bank, the National Bank of Serbia, the central banks of Malta and San Marino, the Republic of Austria and the Republic of Latvia.

This is not a lapse in diligence. There is no company register above a central bank to check it against. It is a reminder that the identifier system assumes a registry underneath every entity, and at the top of each country there is not one.

Why this matters

The LEI is not decoration. It travels in ISO 20022 payment messages, it is required in a widening set of European and American reporting regimes, and screening and onboarding systems use it to tell one legal entity from another.

So the question a payments operator should ask of this data is narrow. If a counterparty's BIC is still live in the scheme register but its LEI has been retired to a successor, which identifier does your system treat as authoritative, and what happens in the four weeks before the scheme register catches up?

On the dates the records carry, the gap these seven sit in is at most four weeks old. It may well close next month. The point is that it exists at all, and that it is visible to anyone willing to join two free files.

What this is not

A retired LEI is a statement about a legal entity, not about operations. Branches, accounts and payment flows normally continue under the successor. Nothing here says a payment failed, a customer was affected or any institution did anything wrong, and HaiPay is not alleging that.

A BIC that resolves to no LEI is not proof the institution has none. It may hold one that is simply not mapped to that BIC. HaiPay did not attempt name matching, so the 7.6% with no match is an upper bound on genuine absence, not a measurement of it.

Lapse periods are computed against 13 October 2026 from the renewal date each record carries. They are the age of the overdue renewal, not a measure of how wrong the underlying data is.

Both registers are amended continuously. These are the figures in the files read on 13 October 2026, against a GLEIF golden copy published the day before.

HaiPay did not contact the European Payments Council, GLEIF or any institution named here.

What to watch

Whether the seven drop out of the EPC register, and how long it takes. That lag is the only part of this that can be measured repeatedly, and it is measurable by anyone, monthly, for free.

Whether VR Bank EifelLand's renewal clears on 15 October. A pending transfer that does not complete becomes a lapse.

And whether the 267 unmatched participants shrink. As the LEI becomes mandatory in more payment and reporting flows, the share of Europe's scheme members that cannot be resolved to a legal identity is the number worth tracking — and today it is roughly one in thirteen.