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That is, "creditor-account" seems to belong more naturally to the TPP message layer than to the Payer layer since Payer have (in C2B transaction NB), no insight in Payee accounts.
Anyway, it seems that you have not fully decided on this:
creditor-account CONDITIONAL: String describing the account of the creditor (IBAN e.g.). Might also be contained within the payment request.
Pardon me, I may be confused, but where is the Payee/Merchant in your scheme?
FWIW, few (if any) other C2B payment request schemes contain this information.
This LinkedIn posting may give you an idea why: https://www.linkedin.com/posts/andersrundgren_the-push-through-wallet-concept-in-a-nutshell-activity-7268884503631122432-9jgN/
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