UPI Fee Model Variables

DSB operates on a cost recovery basis where annual user fees recover the UPI Forecast Total DSB Cost. Annual user fees are derived using a fee model calculation which comprises the variables UPI Forecast Total DSB Cost, Number of Infrequent Users, Number of Standard Users, Search Only API Users and Number of Power Users fixed no later than the end of the first Working Day in December each year, as per the DSB Charges Policy.

2025 UPI Fee Model Variables

As regulatory mandates are still coming into effect during the last quarter of 2024 and throughout 2025, user numbers have been estimated to allow for additional new users who will contribute to the 2025 cost recovery. 

The below UPI Fee Model Variables table will be updated quarterly:

2025 UPI Forecast Total DSB Cost

Fee VariableUser numbers as at 7 Oct 2024
2025 UPI Forecast Total DSB Cost  €12.00m
Number of Infrequent Users 200
Number of Standard Users 64
Number of Search Only API Users 53
Number of Power Users 104

Annual user fees recover the DSB overhead costs which include a 20% margin for financial sustainability, up to the value of six months of working capital. The 2025 UPI Forecast Total DSB Cost includes the UPI Build Costs for the period 2020-2023, Forecast Time-Limited Costs (amortisation of Capex, 2022-2023 Opex and Financing costs) and the Forecast Annualised Operating Expenditure.

In accordance with the DSB Charges Policy, Excess Fee Income resulting from additional contracts, as well as operating cost efficiencies, go to defraying the UPI Forecast Total DSB Cost for the contract year following the audited statutory accounts. Conversely, where the UPI Actual Total DSB Cost exceeds the UPI Forecast Total DSB Cost, creating a shortfall in cost recovery, this will be incorporated into the UPI Forecast Total DSB Cost for the year following the audited financial accounts.

Most fees have increased by 3.5% due to inflation of 4.1% as well as the DSB Board approval of incremental activities which were supported during the annual industry consultation process and to support additional governance related activities. The annual fee values have also been impacted by the different mix in user subscriptions compared to the forecasted mix in October 2023.  

The tables below show the breakdown of the 2025 UPI Forecast Total DSB Cost upon which the 2025 UPI annual user fees have been calculated and includes the 20% margin for financial sustainability.

Category (Recurring)DescriptionAmount
Technology & Operations Operation of the UPI Service through the DSB platform including technical and asset class support€5,746K
ManagementSenior management team including MD and Managed Service Provider management team€522K
AdministrationAdministrative costs and overheads such as office space, and administrative support functions€1,129K
External consultantsExternal oversight, legal, professional & communication€334K
Third-party dataProvision of third-party reference data€599K
Previous Year Operating Expenditure AdjustmentExcess Fee Income reduction based on the DSB Statutory Accounts from prior period (N/A given the 2023 launch of the UPI Service)N/A
Total €8,329K

Forecast Time-Limited Costs (amortisation of Capex, 2022-2023 Opex and Financing costs):

Category (Time-Limited)Amount
Amortised 2022-23 Opex €666K
Forecast Capex Amortisation€2,719K
Financing Costs€287K
Total€3,672K

Amortisation Analysis

1. Capex Amortisation

DSB Build Costs / Capital Expenditure (Capex) are usually amortized over four years, starting from the year after the service/functionality goes live (i.e. 2024-2027), as approved via industry consultation. Due to the number of users subscribing to the UPI Service being below initial estimates (in both user numbers and user types subscribed), the four year amortisation of 2020-2023 build costs will start in 2025 rather than 2024. This approach is being taken as the DSB has an obligation to avoid the potential impact of excessive year on year fluctuations and ensure overall cost stability.

Build Costs are funded by the DSB’s financial sustainability margin with 25% of the cost incorporated into the cost basis for the four years following build of the service/functionality. Build Costs are based on the known evolution of the service which is driven by industry consultation. Therefore, additional Build Costs / Capex for 2026 onwards will be provided when details are known.

2. Amortised 2022-23 Opex

The operational expenditure (Opex) incurred up to 31 December 2023 is amortized over four complete years from 2024-2027. This is to ensure a fair distribution of costs across the broadest user base, and to not disadvantage early adopters.

3. Financing Costs Amortisation Analysis

This is the cost of financing the Capex (Build Costs), initially to be repaid over four years (2024 –2027). Annualised interest represents the total interest from the start of the build phase to the date these costs are fully repaid. Like the capex amortisation, the repayment of this finance cost has been re-profiled over five years (2024-2028) to ensure overall cost stability.

Amortisation Analysis Summary

The below table provides an overview of the amortisation for the period 2025-2028:

Amortisation AnalysisForecast 2025Forecast 2026Forecast 2027Forecast 2028
Amortisation of Forecast Capex, 22-23 Opex and Financing Costs€3,672K€4,122K€3,597K€3,262K

2023-2024 UPI Fee Model Variables

Given the UPI Service launch in Production on 16 October 2023, the DSB estimated the Number of Users per User Type for the 2023 and 2024 invoicing periods based on a market sizing exercise and stakeholder outreach. Further details can be found in the UPI Fee Model Variables and Annual User Fee Update, published September 2023. 

Additionally, as a result of the UPI Service launching in 2023, the actual costs that would normally have been incurred in the 2024 calendar year were spread over five quarters, resulting in the 2024 UPI Forecast Total DSB Cost representing 4/5th of the 2024 cost base.

The below annualised UPI Fee Model Variables table will be updated quarterly:

2024 UPI Forecast Total DSB Cost (1 Jan 2024 – 31 Dec 2024)

Fee VariableEstimated user numbers as at 4 Sep 2023Values as at 31 Dec 2023Values as at 31 Mar 2024Values as at 30 Jun 2024
2024 UPI Forecast Total DSB Cost (representing 4/5th of the 2024 cost base) €9.29m €9.29m   €9.29m €9.29m 
Number of Infrequent Users 10222 84151
Number of Standard Users 6017 4259
Number of Search Only API Users 151638 51
Number of Power Users 12053 87103

Annual user fees recover the DSB overhead costs which include a 20% margin for financial sustainability. The 2023 UPI Forecast Total DSB Cost includes the UPI Build Costs for the period 2020-2023, Forecast Time-Limited Costs (amortisation of Capex, 2022-2023 Opex and Financing costs) and the recurring Forecast Annualised Operating Expenditure for 300 users.

In accordance with the DSB Charges Policy, Excess Fee Income resulting from additional contracts as well as operating cost efficiencies, go to defraying the UPI Forecast Total DSB Cost for the contract year following the audited statutory accounts. Conversely, where the UPI Actual Total DSB Cost exceeds the UPI Forecast Total DSB Cost, creating a shortfall in cost recovery, this will be incorporated into the UPI Forecast Total DSB Cost for the year following the audited financial accounts.

The tables below show the breakdown of the 2024 UPI Forecast Total DSB Cost upon which the 2023-2024 UPI annual user fees have been calculated and includes the 20% margin for financial sustainability. Two columns are provided, the first relating to the annualised billing period 1 Jan 2024 – 31 Dec 2024, and the second for the five quarter billing period 16 Oct 2023 – 31 Dec 2024 (from the date of the UPI Service launch in Production).

Recurring Forecast Annualised Operating Expenditure (Opex) for 300 users:

Category (Recurring)Description1 Jan – 31 Dec 202416 Oct 2023 – 31 Dec 2024
Technology & Operations Operation of the UPI Service through the DSB platform including technical and asset class support€3,500K€4,374K
ManagementSenior management team including MD, Managed Service Provider management team and CFO€403K€504K
AdministrationAdministrative costs and overheads such as office space, and administrative support functions€419K€524K
External consultantsExternal oversight, legal, professional & communication€230K€288K
Third-party dataProvision of third-party reference data€659K€823K
ContingencyContingency to cover unplanned costs to support the service once rolled out€385K€481K 
Previous Year Operating Expenditure AdjustmentExcess Fee Income reduction based on the DSB Statutory Accounts from prior period (N/A given the 2023 launch of the UPI Service)N/AN/A
Total €5,595K€6,993K

Forecast Time-Limited Costs (amortisation of Capex, 2022-2023 Opex and Financing costs):

Category (Time-Limited)1 Jan – 31 Dec 202416 Oct 2023 – 31 Dec 2024
Amortised 2022-23 Opex €694K€867K
Forecast Capex Amortisation€2,350K€2,937K
Financing Costs€654K€818K
Total€3,698K€4,622K

Amortisation Analysis

1. Forecast Capex Amortisation

DSB Build Costs / Capital Expenditure (Capex) are amortized over 4 years, starting from the year after the service/functionality goes live (i.e. 2024-2027), as approved via industry consultation. On this basis, Build Costs are funded by the DSB’s financial sustainability margin with 25% of the cost incorporated into the cost basis for the four years following build of the service/functionality. Build Costs are based on the known evolution of the service which is driven by industry consultation. Therefore, Build Costs / Capex for 2024 onwards will be provided when details are known.

2. Amortised 2022-23 Opex

The operational expenditure (Opex) incurred up to 31 December 2023 is also amortized over 4 complete years from 2024-2027. This is to ensure a fair distribution of costs across the broadest user base, and to not disadvantage early adopters.

3. Financing Costs Amortisation Analysis

This is the cost of financing the Capex (Build Costs), to be repaid over 4 years (2024 –2027). Annualised interest represents the total interest from the start of the build phase to the date these costs are fully repaid (2027). The total has been split over 4 years, as per DSB amortisation policy.

Amortisation Analysis Summary

The below table provides an overview of the amortisation for the period 2023-2027:

Amortisation AnalysisEstimate 2023 16 Oct 2023 – 31 Dec 2024Forecast 2024 AnnualisedForecast 2025 AnnualisedForecast 2026 AnnualisedForecast 2027 Annualised
Amortisation of Forecast Capex, 22-23 Opex and Financing Costs€4,622K€3,698K€3,886K€3,698K€3,698K

*The DSB is committed to maintaining the financial reserves up to the value of 6 months of operating costs. The increase in the amortisation amount in 2025 versus the annualised amount in 2024 is due to collecting the financial sustainability margin required to reach this limit. No financial sustainability margin is applied from 2026 onwards, on the assumption that no further build-up of reserves will be required.

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