The European Commission (EC) has published its second report mandated under Article 27 of the Payments Account Directive 2014/92/EU (PAD), on assembling specific payment related data from Member States on the comparability of fees related to payment accounts, payment account switching and access to payment accounts with basic features (PABFs). The EC highlights that the differences in data collection methods across Member States and that existing data gaps make it difficult to draw firm conclusions about the extent of PAD's benefits to European consumers, though the report offers some tentative findings. The report covers information relating to 2022 and 2023, as well as complete data for 2021 that was not available at the time of the first report. The report confirms general compliance by payment service providers with Articles 4, 5 and 6, which require the provision of standardised fee information, annual fee statements and consistent terminology in consumer communications. Most Member States also have operational comparison websites as required under Article 7, with websites updated regularly and some offering information through various communication channels and public campaigns, helping to raise consumer awareness.

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The UK Financial Conduct Authority has published its quarterly consultation paper No 49, accompanied by a new webpage, inviting key feedback on proposed amendments to its Handbook.
Key proposals include:

• Broadening the scope of the FCA's Decision Procedure and Penalties Manual on penalties policy to include the Private Intermittent Securities and Capital Exchange System (PISCES).
• Removing most statutory declarations from mutuals registration function forms to reduce the time and expense involved for mutual societies submitting applications to the FCA.

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The Wolfsberg Group has published comprehensive guidance on managing financial crime risks for financial institutions (FIs) that provide banking services to fiat-backed stablecoin issuers. While recognising the legitimate benefits of stablecoins, such as pseudonymity, rapid settlement and global reach, the Group also highlights that these same benefits introduce unique risks. The guidance therefore introduces a risk-based framework for assessing and monitoring relationships with issuers operating in regulated jurisdictions. It notes that although existing financial crime risk management principles remain applicable, existing controls may require adapting to address the specific risks posed by stablecoin issuers. The guidance introduces the relevant terminology used by the Group on stablecoins and describes the typical fiat-based services an FI may offer to a stablecoin issuer, highlighting how financial crime-related controls may require adjustment. It also explains how, under a risk-based approach, an FI may evaluate the issuer's compliance obligations on the blockchain. Ultimately, the Group's view is that the approach to banking a stablecoin issuer mirrors that of any customer relationship: firstly to identify and understand the risks associated with both the customer and the nature of the relationship, as well as evaluate how the issuer manages those risks; secondly to determine whether the issuer's risk profile and mitigation strategies align with its own risk appetite; and finally, the FI should implement a proportionate risk management framework that enables ongoing monitoring of the issuer's behaviour and supports timely corrective action when necessary.

HM Treasury (HMT) has published a consultation paper "A Streamlined Approach to Payment Systems Regulation" seeking views on its proposals on the consolidation of the UK Payment Systems Regulator's (PSR) functions within the UK Financial Conduct Authority (FCA). The move, announced in March as part of the UK government's broader Regulatory Action Plan, aims to simplify the regulatory framework to help support growth, better manage burdens on businesses and minimise overlaps between regulators' responsibilities. Under the proposal, the FCA will assume the PSR's responsibilities, including on promoting competition and innovation, and supporting consumer protection in payment systems. Transitional work is already underway, and the consultation now sets out the government's proposed policy approach.

Key things to note include:

• HMT intends to align the PSR's functions within the FCA's existing framework under the Financial Services and Markets Act 2000 (FSMA 2000), to the extent this is practicable. Where full integration is not feasible, the relevant functions are expected to be set out in a new part of FSMA 2000.

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The BIS Innovation Hub London Centre, in collaboration with the Bank of England, has announced the launch of Project Keystone, an initiative exploring how technology can enhance the analytical use of ISO 20022 data. 93% of payment system operators have either implemented or are preparing to implement ISO 20022. Project Keystone aims to support this transition by offering a standardised data analytics platform focused on ISO 20022 data. The tool comprises two modules: one for managing the complex data structure and storage needs of ISO 20022, and another for conducting data-driven analysis. Keystone is intended to be an off-the-shelf component for payment system operators to integrate into their own systems, enabling enhanced use of enriched payments data. Central banks and other regulatory bodies could leverage this to gain deeper insights into real-time economic activity, monitor system-wide liquidity and enhance participant confidence, including ensuring adherence to the ISO 20022 standard itself.

The UK Payment Systems Regulator (PSR) has published its annual report and accounts for 2024/25, summarising the PSR's progress across its key activities over the year. In March, the UK government announced that the PSR would consolidate into the UK Financial Conduct Authority (FCA) to streamline regulation and enhance efficiency. While legislation is pending, the report highlights the transitional work already underway to support a more streamlined approach. You may like to read our opinion piece "UK Payment Systems Regulator to be abolished - what's next?" which explores key considerations and potential impacts of the transition. The PSR's annual report sets out significant achievements in its work over the past year, including in fraud prevention through the reimbursement requirement for authorised push payment fraud scams, resulting in 99% of victims being reimbursed in the first three months.

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The European Banking Authority has published three single rulebook Q&As relating to Commission Delegated Regulation (EU) 2018/389 supplementing the revised Payment Services Directive 2 (Directive 2015/2366/EU), specifying regulatory technical standards on strong customer authentication (SCA) and secure communication. The Q&As cover: (i) whether payment initiation service providers can access payment status information without encountering obstacles (2024_7261); (ii) the manner in which corporate clients of account servicing payment service providers can use proxy matrices to invoke the services of third party providers (2024_7265); and (iii) whether an application programming interface key can constitute a knowledge element of SCA (2024_7286).

The Bank of England (BoE) has published its 2024/25 annual report for the Real-Time Gross Settlement (RTGS) system and CHAPS, marking the successful completion of the RTGS Renewal Programme with the launch of RT2 in April. RT2 introduces a new core ledger and settlement engine, enhancing resilience, security, and functionality, including ISO 20022 messaging and extended automation. Looking ahead, the BoE is shifting towards an "ongoing programme of change" focused on continuous improvement to further strategic deliverables. This includes the following as set out below.

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The UK Payment Systems Regulator (PSR) has published its decisions to revoke:

• From 27 August, Specific Direction 2, which requires all central infrastructure for Bacs to be competitively procured (and Specific Direction 2a which varied the requirement). This decision stems from work to deliver the National Payments Vision (NPV) and aims to provide the necessary space and certainty for work to deliver the NPV.
• From 25 August, Specific Direction 4, which requires the operator of the LINK payment system to procure any future contracts for central infrastructure services in a competitive manner (and Specific Direction 4a which varied the requirement). This decision aims to ensure that LINK and its members have the regulatory clarity they need to focus on their longer-term sustainability and the delivery of an efficient network, given that due to changes in market conditions, a competitive tender obligation may no longer be an effective way to address the competition issues.

The Bank of England (BoE) has published a new webpage on the national payments vision and the vision engagement group (VEG) of sector representatives supporting delivery of the vision. The webpage on the national payments vision contains an update on the delivery of the next generation UK retail payments infrastructure to date and next steps in 2025, focusing on key deliverables in H2.

• In September: i) The BoE will communicate further on the establishment of the Retail Payments Infrastructure Board (RPIB), and the application process for membership of RPIB; ii) The Bank, HM Treasury, FCA and PSR will engage with VEG members to discuss the Payments Vision Delivery Committee's strategy, which is due to be published later in the autumn.
• In October and November: i) The BoE will appoint members to the RPIB with a view to holding the first meeting of the RPIB in late October; ii) The BoE will also set out an approach to wider stakeholder engagement across the ecosystem for the RPIB beyond 2025, and the processes to deliver an early 2026 RPIB consultation paper; iii) The Payments Vision Delivery Committee plans to publish its strategy for retail payments infrastructure. This will inform the early 2026 RPIB consultation paper.
• In December: The Payments Vision Delivery Committee will publish the Payments Forward Plan by the end of the year.

The UK Financial Conduct Authority (FCA) has published a feedback statement on the design of the Future Entity for UK open banking (FS25/4). The feedback statement responds to the feedback received to the consultation, which was issued by the Joint Regulatory Oversight Committee (JROC). However, in line with the National Payments Vision, JROC has been wound down and the FCA is progressing the further development of open banking. In the feedback statement, the FCA states that subject to legislation the Future Entity will be the primary standard setting body for open banking Application Programming Interfaces (APIs) in the UK. It will set common standards for a minimum level of service and interoperability across open banking services, monitor API performance and compliance with standards (although it will not have enforcement powers), provide directory and certification services and assist in development standards to enable commercial schemes. It is not envisaged that the Future Entity will own or operate commercial schemes where market innovation incentives exist. The FCA expects that the Future Entity and commercial scheme operators will be regulated as interface bodies under the Data (Use and Access) Act. The FCA intends to progress the design of the Future Entity, which is intended to be established by the end of the year.

The UK Financial Conduct Authority (FCA) has published a policy statement (PS25/12) setting out changes to the safeguarding regime for payments and e-money firms. The FCA consulted on the proposals in CP24/20 in September 2024. The changes to the rules are in the Payment and Electronic Money (Safeguarding) Instrument 2025 (FCA 2025/38) which will come into force on 7 May 2026, allowing for an implementation period of nine months (an extension to the originally proposed six months). In addition, the FCA also published the proposed related amendments to its payment services and e-money approach document.

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The Bank of England (BoE) has published a consultation paper outlining Phase 1 of its extension to settlement hours for the UK's renewed Real-Time Gross Settlement system (RT2) and CHAPS. RT2 went live in April. The BoE has concluded that the existing 6am to 6pm window for settlement no longer meets industry needs, which operate on a 24x7 basis. The BoE is proposing to extend CHAPS opening hours in phases, with the goal of near 24x7 settlement for RT2 and CHAPS by the end of the decade.

The BoE's Phase 1 consultation proposes opening CHAPS for settlement from 1:30am on existing business days for urgent and non-urgent settlement of any payment available for settlement, with implementation targeted for the second half of 2027. The consultation also seeks early views on extending the CHAPS contingency window from its current hours of 6pm–8pm to 6pm–10pm, and on introducing RT2 settlement on certain bank holiday weekends. The deadline for responses on the consultation is 21 October.

The BoE plans to publish a policy statement on the 1:30am CHAPS extension in early 2026, as well as a Phase 2 consultation paper seeking views on the evening contingency extension and bank holiday settlement. A policy statement on the latter is also expected next year.

Commission Decision amending Decision 2011/C 253/04 of 29 August 2011 has been published in the Official Journal of the European Union. The amendment, adopted on 25 July, extends the mandate of the Payment Systems Market Expert Group (PSMEG) from 31 December 2025 to 31 December 2030. The PSMEG is comprised of a broad range of payment service providers and users, advising the European Commission on policy development and implementation in the payments sector. The extension reflects the continued need for expert input amid rapid innovation, technological progress and evolving market developments.

The National Crime Agency (NCA) and the UK Financial Conduct Authority (FCA) have jointly published a set of nine system priorities to combat economic crime in the UK, in line with the UK's second Economic Crime Plan and the National Risk Assessment. Backed by the Home Office, HM Treasury, the National Economic Crime Centre and UK Finance, the priorities seek to enhance public-private collaboration, enabling regulated firms to allocate resources more effectively while maintaining compliance. Key focus areas include money laundering through UK corporate structures linked to certain jurisdictions; fraud originating from international offenders; exploitation of money mules; and criminal cash consolidation via UK banking channels.

Additional priorities target terrorist financing; sanctions evasion by professional enablers; abuse of power by overseas Politically Exposed Persons; and the resilience of the cryptoasset ecosystem against criminal abuse. The only predicate offences explicitly listed in these priorities are those which fall under the definition of economic crimes—namely fraud, sanctions evasion and terrorist financing. However, the priorities concerning money laundering methods are intended to apply to all potential predicate offences, including but not limited to organised immigration crime, drug and firearms offences and human trafficking. A newly established System Prioritisation Governance Group will oversee governance of the priorities, with further guidance expected to be published in due course to support firms in aligning with these objectives.

The UK Financial Conduct Authority (FCA) has published consultation paper CP25/23, alongside a press release and new webpage, setting out its proposed rules for regulating Deferred Payment Credit (DPC), commonly known as Buy Now Pay Later (BNPL). In the paper, the FCA uses "DPC" to refer specifically to the interest-free, short-term credit products. The deadline for comments on the FCA's consultation is 26 September, with a final policy statement expected in early 2026. The rules will apply from 15 July 2026.

The Financial Services and Markets Act 2000 (Regulated Activities etc.) (Amendment) Order 2025 brings interest-free BNPL agreements within the regulatory perimeter. This means that from 15 July 2026, third-party lenders offering DPC must be FCA-authorised or hold temporary permission under the temporary permissions regime (TPR). The TPR allows firms to continue operating while the FCA assesses their applications. Firms without authorisation or temporary permission must cease regulated DPC activity but may continue servicing DPC agreements entered into before that date. Merchants offering DPC directly will remain outside the regulatory perimeter and will not require authorisation.

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Following its November 2024 consultation, the Bank of England (BoE) has published final fundamental rules for financial market infrastructure firms (FMIs), a supervisory statement setting out how the BoE expects FMI to comply with the rules and a final policy statement providing its responses to the feedback to the November proposals. FMIs include central counterparties (CCPs), central securities depositories (CSDs) and recognised payment system operators. The final rules take effect on 18 July 2026. In response to consultation feedback, the BoE makes refinements to the policy which include.

• Clarification that FMIs are not expected to take actions to mitigate systemic risk if doing so would compromise their own resilience.
• Increased emphasis on the importance of transparency between FMIs with their participants to enhance effective risk management.
• Clarification on the application of the fundamental rules to activities conducted at the group level.

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HM Treasury has published its latest 2025 National Risk Assessment (NRA) of Money Laundering and Terrorist Financing, offering a comprehensive review of the UK's exposure to financial crime. Building on the 2015, 2017, and 2020 assessments, the 2025 NRA evaluates: (i) the UK's AML/CFT framework and the government's response to the 2020 NRA; (ii) overarching money laundering (ML) risks; (iii) overarching terrorist financing (TF) risks; (iv) sector-specific ML/TF risks under the Money Laundering Regulations (MLRs); and (v) emerging cross-cutting risks outside MLR-regulated sectors.

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The UK Payment Systems Regulator (PSR), in conjunction with the UK Financial Conduct Authority (FCA), has published its regulatory fees figures for 2025/26. The annual funding requirement is set at GBP27 million, with fees allocated based on transaction volume (80%) and value (20%) across regulated payment systems for the 2024 calendar year. The PSR confirms that the ongoing consolidation into the FCA will be managed within existing budgets, with no immediate fee increases planned. The minimum fee threshold remains at GBP 100, and special project fees may apply to for-profit payment system operators. Fee payers are required to submit transaction data by 1 March, with invoices issued from July and final payments due within 30 days of receipt. The PSR confirms its fee methodology remains consistent with prior policy statements PS18/12 and PS23/2.

HM Treasury has published an update on the National Payments Vision (NPV), announcing plans to implement a new collaborative model for delivering the UK's next-generation retail payments infrastructure. The Payments Vision Delivery Committee (the Committee), established to strengthen regulatory coordination and lead key activities, has agreed the new model which will redefine roles across the payments ecosystem, establishing clear responsibilities for public authorities and industry to accelerate the renewal of the UK's retail payments infrastructure and capitalise on emerging technologies. The model also supports short-term activity to improve resilience and functionality of the existing Fasters Payments System, which Pay.UK has been progressing in the industry. Pay.UK will continue its role as operator of existing systems, while contributing its expertise to the evolving framework. The Bank of England (BoE) will establish and chair the Retail Payments Infrastructure Board, which will oversee delivery of the infrastructure alongside the Committee, Pay.UK and a newly formed Delivery Company. The Committee will publish its full strategy for retail payments infrastructure in autumn of this year, with a Payments Forward Plan expected by the end of the year. The BoE published its own statement and the UK Payment Systems Regulator also issued a separate update on its webpage.

HM Treasury has published a policy paper on the wholesale financial markets digital strategy. The purpose of the strategy is to ensure the UK benefits from opportunities to improve its wholesale financial markets, by using new technologies effectively. This policy spans trading venues, clearing houses, settlement systems, payment systems and other elements of the UK's financial ecosystem that support the operation of financial markets. The policy is structured as focusing on three areas: (i) market optimisation – which includes removing paper-based and manual processes, and using data effectively; (ii) market transformation – which centres on proactive innovation for new models across the range of market activities and includes taking forwards the issuance of the UK's digital gilt instrument (DIGIT) using distributed ledger technology (please see above for HM Treasury's policy paper for further detail); and (iii) market leadership – where the UK government has committed to working with the sector to develop a cross-cutting approach which will seek to reduce potential fragmentation and regulatory barriers, and to appointing an industry expert "Digital Markets Champion".

The UK statutory instrument (The Financial Services and Markets Act 2000 (Regulated Activities etc.) (Amendment) Order 2025) implementing the necessary legislative changes for progressing buy-now, pay-later (BNPL) regulation was made, accompanied by an explanatory memorandum. The draft secondary legislation was originally laid in May alongside HM Treasury's (HMT) response to its 2024 consultation. The instrument brings interest-free BNPL agreements within the regulatory perimeter by amending the scope of agreements which are capable of being "exempt agreements" under article 60F of the Financial Services and Markets Act 2000 (Regulated Activities) Order 2001. In addition, it provides a carve-out from the regulated activity of credit broking for merchants offering BNPL agreements except in the case of domestic premises suppliers.

The instrument came into force on 15 July for certain limited purposes, including to enable the UK Financial Conduct Authority and the UK Financial Ombudsman to make rules and give guidance in relation to the changes. For other purposes, the instrument comes into force on 15 July 2026 which is in line with the expected timetable for BNPL regulation. You may also like to read our client bulletin, Buy-Now, Pay Later – The Journey Continues (and the end is nearly in sight) for further detail on HMT's response to the 2024 consultation on BNPL products.

Regulation (EU) 2025/1355 of the European Central Bank (ECB) adopted on 2 July has been published in the Official Journal of the European Union. This Regulation recasts and replaces Regulation (EU) No 795/2014, updating the oversight framework for systemically important payment systems (SIPS) in the euro area. It strengthens the ECB's supervisory role by aligning it with international standards, particularly the CPMI-IOSCO Principles for Financial Market Infrastructures. The Regulation applies to both large-value and retail payment systems, operated by either central banks or private entities. However, Eurosystem-operated SIPS are exempt from certain requirements (such as those relating to governance, wind-down planning, capital and liquidity buffers, collateral, and investment risks) where equivalent internal ECB rules already apply.

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The Proceeds of Crime (Money Laundering) (Threshold Amount) (Amendment) Order 2025 has been made and published with an accompanying explanatory memorandum. The legislation increases the financial threshold under sections 339A(2) and 339A(6A) of the Proceeds of Crime Act 2002 (POCA) from GBP1,000 to GBP3,000. These thresholds apply to two key exemptions for regulated businesses, such as banks, electronic money institutions and payment institutions, among others set out in schedule 9 of POCA, enabling them to (i) operate a customer account; or (ii) return funds when terminating a customer relationship, without committing a money laundering offence, even where criminal property is suspected (i.e., property believed to represent the proceeds of crime), provided the amount involved is below the threshold. The change aims to reduce the volume of low-value Defence Against Money Laundering (DAML) Suspicious Activity Reports (SAR), which in 2024 accounted for 23,000 submissions but only 0.1% of assets denied. A DAML SAR can be submitted for transactions above the threshold, which means a criminal offence will not be committed by the regulated entity, although the transaction is frozen pending the outcome of the review of the transaction or the lapse of three months. A review of the exit and pay away exemption introduced via the Economic Crime and Corporate Transparency Act 2023 is scheduled for 2026.

The UK All-Party Parliamentary Group (APPG) on Fair Banking has published its latest report, "No Half Measures – A Blueprint to Beat APP Fraud", alongside a press release. The report assesses the UK's response to authorised push payment (APP) fraud and the early impact of the mandatory reimbursement requirement (MRR) introduced by the UK Payment Systems Regulator (PSR) in October 2024. The APPG recognises the MRR as a step forward in consumer protection but emphasises that it is not a complete solution to fraud. Key gaps remain, particularly in areas such as cryptocurrency platforms and international transfers, which remain outside the scope of the current reimbursement framework. The APPG calls for a balanced, system-wide approach, urging collaboration to effectively combat APP fraud rather than placing disproportionate expectations on financial institutions alone. In Q4 2025, there will be an independent one-year review assessing the impact of the MRR, as well as the PSR's wider policy approach to APP fraud.

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The Council of the EU has published initial four-column tables for the two key legislative proposals under the Payment Services Package: (i) the proposed Payment Services Directive (PSD3); and (ii) the Payment Services Regulation (PSR). The tables present, side-by-side, the positions of the European Commission, the European Parliament and Council of the EU, along with a fourth column left blank for Member State comments.

The UK Financial Conduct Authority (FCA) has published the findings of its multi-firm review into risk management and wind-down planning across e-money and payment firms. While the FCA had observed examples of good practice in the structure of firms' wind-down plans (WDPs) and risk management frameworks, it concluded that no firm fully met its expectations and in particular were not adhering to the FCA's finalised guidance. Key areas identified as needing improvement are set out below.

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The UK Payment Systems Regulator (PSR) has published consultation paper CP25/2 alongside a new webpage, proposing the revocation of Specific Direction 4 (SD4) and its amendment, SD4a. SD4, introduced following the PSR's 2016 infrastructure market review, requires the operator of the LINK payment system to procure its central infrastructure every ten years via a competitive process.

The PSR now considers this requirement may no longer be an effective means of addressing competition concerns, due to evolving market conditions (in particular, decreased cash withdrawals and reduced scheme revenues). Instead, the PSR proposes that active regulatory oversight of LINK and its infrastructure provider, Vocalink, would be a more effective way to mitigate risks associated with a monopoly position. The consultation seeks views on the proposed revocation, particularly the risks the removal may create on competition, innovation and end-user outcomes, and how enhanced supervision of LINK and Vocalink could help address them. The deadline for responses is by 5:00pm on 17 July.

The UK Financial Conduct Authority (FCA), Bank of England, Payment Systems Regulator (PSR) and Prudential Regulation Authority have issued a joint statement announcing their revised memorandum of understanding (MoU) on the supervision of payment systems in the UK.

The update follows a review conducted by the authorities in December 2024 which identified opportunities to enhance cooperation among the authorities in overseeing payment systems. The revised MoU aims to clarify the respective roles and coordination mechanisms of the authorities and introduces principles for regulatory cooperation including through regular engagements to share insights on the sector, delivering joint policy initiatives and coordinating supervisory work. The revised MoU reflects the PSR's current responsibilities, notwithstanding the UK government's announcement that the PSR's functions will largely be rolled into the FCA in the future, with no immediate changes being made by the UK Government to the PSR's remit or ongoing work programme.

The UK Government has published a policy paper outlining its industrial strategy. The strategy centres around eight priority sectors (the IS-8), including financial services. The UK government's ambition is to establish the UK as the world's most innovative full-service financial centre by 2035. A dedicated sector plan is expected to be published alongside the mansion house speech on 15 July.

Key measures to achieve this objective include:

• Ensuring financial services enables growth across the real economy, with retail banks and wholesale markets providing credit and liquidity.
• Mobilising pensions capital into the UK.

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The European Banking Authority (EBA) has published a report and accompanying press release, on its review of the regulatory technical standards (RTS) under the Payment Accounts Directive concerning standardised terminology for payment account services. The EBA concludes that the current terminology remains fit for purpose. It acknowledges the growing relevance of instant credit transfers and notes that their inclusion in the RTS may become appropriate in the future, although no immediate changes are deemed necessary. Instead, the EBA proposes revisiting the findings in four years or when significant market or legislative developments occur to ensure the terminology remains relevant and effective.

The Financial Action Task Force (FATF) has published revised standards and an accompanying explanatory note, updating its comprehensive framework on recommendations to strengthen global efforts in anti-money laundering, counter-terrorist financing and counter-proliferation financing, as announced during the joint FATF-MONEYVAL Plenary meeting. The FATF update includes amendments to Recommendation 16, which governs the transparency of wire transfers through the payment chain and is commonly referred to as the "Travel Rule. The revised recommendation is aimed to modernise FATF standards in response to the evolving payments landscape, which now includes a broader range of products and services, technologies and business models.

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HM Treasury has published a policy paper setting out an update to its final position to its 2024 consultation on regulating Buy-Now, Pay-Later (BNPL) products which led to the laying of the draft secondary legislation, The Financial Services and Markets Act 2000 (Regulated Activities etc) (Amendment) Order 2025. Under the draft regulation, domestic premises suppliers (DPS merchants), which are businesses who sell, offer to sell or agree to sell goods or offer to supply or contract to supply services in people's homes, are required to seek credit broking permissions to offer BNPL products as a payment option. However, in response to industry feedback, the UK Government has concluded that this requirement may have a disproportionate impact for small businesses and will potentially reduce consumer choice. Consequently, an amending negative statutory instrument to coincide with the BNPL regulation, will be laid to remove this requirement, while maintaining key consumer protections. These include: (i) BNPL lenders will be required to conduct affordability and creditworthiness checks before consumers can use the product; (ii) consumers will be able to raise complaints through the Financial Ombudsman Service and access protections under section 75 of the Consumer Credit Act; and (iii) BNPL lenders authorised by the UK Financial Conduct Authority (FCA) will be expected to comply with Consumer Duty rules, including regular monitoring and review of consumer outcomes. BNPL firms will also be expected to exercise greater oversight of the merchants using their services—including DPS merchants. The UK government and the FCA will continue to monitor the BNPL market and will take any action, if required, to prevent consumer harm.

HM Treasury (HMT) has published a series of wholesale cash oversights orders (dated 12 June) issued for the purpose of the Bank of England's (BoE) wholesale cash oversight regime. The orders confirm the recognition of several firms under Part 5A of the Banking Act 2009 for their roles in the wholesale cash distribution system. Under the Banking Act 2009, the BoE is accountable for overseeing risks to the effectiveness, resilience and sustainability of wholesale cash distribution across the UK, or any part thereof. The firms recognised include Vaultex UK Limited, G4S Cash Centres (UK) Limited, Post Office Limited, National Westminster Bank Public Limited Company, The Royal Bank of Scotland Public Limited Company, Lloyds Bank PLC, Bank of Scotland PLC, Barclays Bank UK PLC, Barclays Bank PLC, HSBC UK Bank PLC, HSBC Bank PLC and Santander UK PLC.

The Payment Services and Payment Accounts (Contract Termination) (Amendment) Regulations 2025 (SI 2025/688) have been published, alongside an explanatory memorandum. The regulations amend regulation 51 of the Payment Services Regulations 2017 (PSRs) to strengthen consumer protections when banks and payment service providers (PSPs) terminate payment service contracts. Under the new rules, PSPs must now provide customers at least 90 days' notice—an increase from the two months currently required—before closing a customer's account or ending a payment service contract. They must also give a clear, specific written explanation for the termination, enabling customers to understand the decision and, if necessary, challenge it through the Financial Ombudsman Service.

The aim is to prevent arbitrary account closures, enhance transparency and support small businesses by giving them more time to secure alternative banking arrangements, reinforcing the government's commitment to economic growth and security under the Plan for Change.

The regulations also amend regulations 25 and 26 of the Payment Accounts Regulations 2015 to bring the notice period and the requirement to provide reasons for terminating basic bank account contracts in line with the updated PSRs. Banks will also need to provide reasons for refusing an application for a basic bank account.

The legislation enters into force on 28 April 2026 and will apply to contract terminations and bank account closures for contracts agreed from and including 28th April 2026.

The Council of the European Union has announced it has adopted its negotiating mandate for the proposed Payment Services Directive (PSD3) and Payment Services Regulation (PSR), collectively known as 'the Payment Services Package'. The legislative package aims to modernise the EU's regulatory framework for payment services, building on the foundations of PSD2 to enhance consumer protection, strengthen fraud prevention and improve the functioning of open banking. It also seeks to address the pending challenges in the context of the impact and application of PSD2 in the internal market and adapt it to align with new market developments. Once formally agreed by both the Council of European Union and the European Parliament, the proposals will establish the PSR, which will be directly applicable in the EU and will repeal PSD2, replacing it with PSD3. We discuss the Payment Services Package in our bulletin, "Combatting payment account fraud - latest regulatory developments from the European Union."

The Decision (EU) 2025/1148 of the European Central Bank (ECB) adopted on 2 June, has been published in the Official Journal of the European Union. This decision amends Decision (EU) 2025/222 concerning access by non-bank payment service providers (NB-PSPs), namely payment institutions and electronic money institutions, to central bank operated payment systems, including TARGET. Due to delays by some member states in transposing the relevant EU directives into national legislation, the ECB has decided to defer the date from which NB-PSPs can request access to TARGET from 16 June to 6 October. Additionally, the transition period for NB-PSPs to migrate to from their current status (e.g., as addressable BIC holders or reachable parties) to full TARGET participants has been extended from 31 December to 31 March 2026. To ensure a smooth transition, the decision enters into force immediately following its publication in the Official Journal of the European Union.

The European Banking Authority (EBA) has issued an opinion (referred to as the No Action letter) in response to a request from the European Commission (EC) in December 2024, on the interplay between Payment Services Directive (PSD2/3) and Markets in Crypto-Assets Regulation (MiCAR) in relation to electronic money tokens (EMTs). It seeks to clarify how national competent authorities (NCAs) should approach the authorisation and supervision of crypto-asset service providers (CASPs) that engage in EMT-related activities during the transitional period before PSD3 and the Payment Services Regulation (PSR) come into effect. The EBA advises the EC, European Council and European Parliament to avoid long-term dual authorisation requirements and advises NCAs to require PSD2 authorisation only after a transition period ending on 2 March 2026, and only for a defined subset of CASPs—specifically those providing services such as the custody and administration of EMTs or facilitating EMT transfers on behalf of clients. NCAs are encouraged to adopt streamlined authorisation procedures that leverage information already submitted during the MiCAR process. Post-transition, NCAs must ensure entities who are not licensed as a payment service provider (PSP) or have not entered partnership with a PSP, are prevented from providing EMT related services that qualify as a payment service.

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The European Central Bank (ECB) has published a consultation paper (CP) exploring the extension of operating hours for its real-time gross settlement (RTGS) system, T2. This involves both its daily operational hours and its operational days, while also considering the potential interaction with the operating hours of TARGET2-Securities (T2S), even though T2S is generally outside the scope of the consultation. T2's operating hours were extended previously in 2023, but the ECB is consulting on a further extension given the growing liquidity management challenges for banks due to increasing use of instant payments and the potential introduction of a digital euro.

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The UK Law Commission has published a consultation on reforms to private international law necessitated by emerging technologies such as decentralised ledger technology (DLT). The Law Commissions state that their project has a particular focus on crypto-tokens, electronic bills of lading and electronic bills of exchange because these assets are prevalent in market practice while also posing novel theoretical challenges to the methods by which issues of private international law have traditionally been resolved. The consultation focuses primarily on wholly decentralised applications of DLT. Among other things, the Law Commission proposes:
 

1. To create a new free-standing information order to help claimants who have lost crypto-tokens through fraud or hacking, obtain information about the perpetrators or the whereabouts of their tokens without having to go through the existing gateways.

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The UK Payments Systems Regulator (PSR) has published a consolidated policy statement (PS25/5) concerning the authorised push payment (APP) fraud reimbursement requirement within the Faster Payments system, which came into effect on 7 October 2024. The document brings together previous publications on the reimbursement requirement to serve as a single point reference for stakeholders seeking to understand the policy and how it may impact them. The statement acts as general guidance to aid interpretation of the policy. The policy statement has also included FAQS on aspects of the APP scam reimbursement policy and, except where otherwise indicated, also applies to the requirements for reimbursement of APP fraud committed over the CHAPS payment system.

HM Treasury (HMT) has published a response to its 2024 consultation on regulating Buy-Now, Pay-Later (BNPL) products and laid the draft secondary legislation (Financial Services and Markets Act 2000 (Regulated Activities etc) (Amendment) Order 2025), to implement the proposed regime before Parliament. The consultation response is accompanied by an updated webpage and press release. The proposed regulatory framework aims to bring BNPL products under the UK Financial Conduct Authority's (FCA) oversight, ensuring consumers receive clear information, undergo affordability checks, have access to the Financial Ombudsman Service and benefit from the protections of section 75 of the Consumer Credit Act (CCA)—which imposes liability upon a creditor for breaches by a supplier—should something go wrong with their purchases.

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The UK Payment Systems Regulator (PSR) has published an update on what it has seen since the implementation of its authorised push payment (APP) fraud reimbursement scheme in October 2024. The data covers UK payments made via the Faster Payments system from the start of the reimbursement policy (7 October 2024) to the end of 2024.

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The European Central Bank (ECB) has announced that the amendment to the TARGET Guideline, which would allow non-bank payment service providers (non-bank PSPs) to participate in TARGET is postponed. This has resulted from delays in some euro area countries in transposing the required amendments to the Settlement Finality Directive and revised Payment Services Directive (PSD2) into their national legislation. The amendment, outlined in Decision ECB/2025/2, is now expected to enter into force in October.

The Bank of England (BoE) has published a speech by Sarah Breeden, Deputy Governor for Financial Stability, at the Point Zero Forum. The subject of the speech was the digitalisation of money and assets, and in particular the BoE's focus on interoperability. In terms of general commentary, Ms Breeden highlighted the need to collaborate closely with international partners to ensure safe innovation and support for firms with cross-border transactions. She also emphasised the importance of enabling users to switch seamlessly between different forms of money and across asset classes. To drive interoperability, harmonised technical standards and working with the public sector is needed to understand further how to integrate these new, digital forms of assets and money into the wider financial system.

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The UK Payment Systems Regulator (PSR) has published its annual plan and budget for 2025/26. The foreword by Aidene Walsh, Chair of the PSR, references the government's announcement to incorporate the PSR into the FCA and how, while full transfer of responsibilities requires legislation, the PSR has where sensible already commenced the process of further alignment and consolidation with the FCA as it awaits the outcome of the consultation being run by HM Treasury (HMT) in the coming months. David Geale, Managing Director, reiterates that HMT has made it clear that the PSR retains its full suite of powers pending changes in legislation, and the PSR intends to use them to deliver against its work programme and commitments. This includes completing phase one of the rollout of variable recurring payments, completing an evaluation of its APP reimbursement requirements, implementing the remedies following its card reviews and working with industry to unlock innovation and growth. The PSR will work with the Bank of England to drive infrastructure upgrades, as per the direction set by the government in the National Payments Vision (NPV). You may like to see our article, "Payment Services and Payment Systems" in which we discuss, among other things, the NPV in more detail.

The UK Financial Conduct Authority (FCA) has published examples of good and poor practices following its review into international payment pricing transparency. Under the consumer duty, in line with the FCA's Handbook (PRIN 2A.5.3R), firms are required to communicate information to retail customers in a way which is clear, fair and not misleading. The FCA reviewed the websites of a sample of firms offering UK customers international money remittance and cross-border payments and found that only some firms clearly displayed the amount recipients would receive, along with detailed fees and charges. Many firms did not, making it difficult for customers to compare prices and make informed decisions. Transaction fees, additional intermediary bank fees and variable fees were also not usually clearly displayed. As a result of these findings, the FCA sets out examples of good and bad practices to help firms improve their communication practices with consumers and deliver better outcomes for retail customers. The FCA expects firms to comply with their obligations under the consumer duty by regularly monitoring the effectiveness of their communications, to assist consumers in understanding costs and making informed decisions. The FCA is likely to undertake future work in the area to understand what improvements have been made.

The International Organization of Securities Commissions (IOSCO) and the Committee on Payments and Market Infrastructures (CPMI) has published a report, alongside a press release, evaluating the EU's implementation of the Principles for Financial Market Infrastructures (PFMI) for systemically important payment systems (PSs), central securities depositories (CSDs) and securities settlement systems (SSSs), collectively referred to as "financial market infrastructures" (FMIs). The report sets out conclusions using a level 2 peer assessment to determine whether, and to what degree, the contents of the EU's legal, regulatory and oversight framework are complete and consistent with the PFMI. Due to the distinct regulatory frameworks for PSs in the euro area and Sweden, which differ from the EU-wide regime for CSDs/SSSs, they were assessed individually. The report concludes that the EU's legal, regulatory and oversight frameworks are complete and consistent with the PFMI in most aspects for PSs, although identified areas for improvement, particularly in risk and governance principles relating to CSDs and SSSs. The assessment reflects the status of implementation as of 30 October 2019, although Annex C to the report discusses the EU's amendments to the CSR Regulation (CSDR Refit) and concludes that this leads to an even greater consistency of the EU regulatory framework with the PFMI and will help authorities address some of the gaps identified in this assessment.

The HM Treasury (HMT) has published a draft statutory instrument introducing new rules requiring banks and payment service providers (PSPs) to give customers at least 90 days' notice before closing their account or terminating a payment service—an increase from the two months currently required. The draft Payment Services and Payment Accounts (Contract Termination) (Amendment) Regulations 2025 is accompanied by an explanatory memorandum, and aims to protect customers from arbitrary account closures and ensures they receive a clear, written explanation, allowing them to challenge decisions through the Financial Ombudsman Service. The new rules will also support small businesses by providing more time to find alternative banking solutions, reinforcing the government's commitment to economic growth and security under the Plan for Change. Subject to Parliamentary approval, the legislation is expected to come into force in April 2026 and will apply to all PSPs terminating payment service contracts without a definite expiry date, including bank account closures, for contracts agreed from and including 28th April 2026. Certain exceptions will apply, for example, to enable PSPs to comply with their obligations under financial crime law.

The Financial Services Regulatory Initiatives Forum (the Forum) has published the Regulatory Initiatives Forum Grid (the Grid), with the UK Financial Conduct Authority (FCA) also updating its webpage. The previous Grid was due to be published in May 2024 but was postponed due to the General Election, meaning the Forum published only an interim update in October 2024.

The 2025 Grid sets out the regulatory pipeline for the next 24 months and reflects the reprioritisation that has taken place since the new government came into power. Notable initiatives include:

• motor finance commission review: the FCA intends to confirm, within six weeks of the Supreme Court's decision on past use of discretionary commission arrangements by motor finance firms, whether it will propose a redress scheme;
• liquidity risk management in funds: the FCA will consult on refined proposals regarding liquidity risk management in funds to implement FSB and IOSCO guidelines;
• Consumer Composite Investments (CCI) Regulation: the FCA published a second consultation paper on the new CCI regime on 16 April (see our update) and plans to issue a Policy Statement with final rules in late 2025;

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