The UK Financial Conduct Authority (FCA) has published a new webpage with guidance aimed at improving the quality of applications for authorisation and registration by payments firms and digital asset firms. The FCA outlines its regulatory expectations through a series of video guides covering common deficiencies and best practices. For both payments firms and digital asset firms, the videos cover the role of a Money Laundering Reporting Officer (MLRO), highlighting common anti‑money laundering compliance gaps and fitness and propriety standards, and the application process for authorisation. Other video guides are directed specifically at payment firms, focusing on how firms (including e-money firms) can prevent financial crime through business‑wide risk assessments, senior management responsibilities and controls against authorised push payment fraud, as well as on demonstrating an effective governance structure as part of an application for authorisation.

The Bank of England (BoE) has published its policy statement confirming the fees regime for financial market infrastructure (FMI) supervision for the 2025/26 fee year, following its October 2025 consultation. The BoE confirms that it will adopt the proposals set out in the consultation paper, including:

• Maintaining existing fee ratios across FMI categories and introducing a new Category 3 for UK payment systems, to align with other FMI types where this categorisation already exists. The BoE will provide further detail on the timing for applying the new fee ratios and implementing Category 3 in the 2026/27 FMI fees consultation paper, which is expected in April (rather than October as in previous years), following stakeholder feedback requesting earlier consultations on future annual fees. This approach will be maintained going forward.
• Increasing certain fees, notably for central counterparties (CCPs) and central securities depositories, to reflect expanded policy and rule‑making responsibilities under the Financial Services and Markets Act 2023, and to recover one‑off costs associated with developing the UK CCP rulebook over a three‑year period.

The BoE also confirms updated hourly rates for special supervisory projects, the treatment of under‑ or overspends from the 2024/25 fee year, and that enforcement fine revenues cannot be used to offset supervisory costs. It also confirms that HM Treasury are exploring options to increase the statutory fee cap for payment systems in future and will consult on any proposals in due course.

The European Central Bank (ECB) has announced a collaboration with the ONCE Foundation for Cooperation and Social Inclusion of People with Disabilities to ensure that the proposed digital euro is accessible to all users, including people with disabilities, older adults and those with limited digital skills. Under the agreement, the ECB will benefit from the foundation's expertise in providing technical advice on accessibility requirements and features for the digital euro application, collaboration on its design and testing accessibility functionalities in early prototypes once available. The collaboration aims to exceed the minimum legal requirements under the European Accessibility Act. The ECB intends to embed accessibility considerations from the earliest stages of design and development, ensuring that the application is clear, understandable and easy to navigate. The outcome of this work could also inform user experience requirements for payment service providers.

The European Banking Authority (EBA) has issued an opinion advising national competent authorities (NCAs) on how to proceed when the transition period (under its no-action letter of 2 June 2025) ends on 2 March. This transition period currently allows cryptoasset service providers (CASPs) to continue providing services involving electronic money tokens (EMTs) that qualify as payment services while submitting, and awaiting the response to, their application for authorisation under PSD2.

The opinion:

• Outlines the conditions under which NCAs are advised to allow CASPs to continue providing EMTs that qualify as a payment service after 2 March, while they do not (yet) hold a license under PSD2.
• Advises NCAs to require CASPs that do not meet all of these conditions to discontinue the provision of such EMT services.
• Advises NCAs to cooperate with the relevant NCA under MiCAR and/or other national enforcement authorities to ensure compliance.

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The UK Financial Conduct Authority (FCA) has published final policy statement PS26/1 setting out its final rules for regulating Deferred Payment Credit (DPC), commonly known as Buy Now Pay Later (BNPL). This follows the July 2025 consultation and the related statutory instrument (Financial Services and Markets Act 2000 (Regulated Activities etc.) (Amendment) Order 2025) which brings interest-free BNPL agreements offered by a third part lender within the regulatory perimeter. This means that from 15 July ("regulation day"), relevant DPC agreements can only be entered into by firms already holding the relevant FSMA permissions or who have successfully applied under the temporary permissions regime (TPR), which allows firms to continue operating while the FCA assesses their applications. All merchants undertaking credit broking activities in relation to DPC agreements, including domestic premises suppliers, remain exempt from the need to be authorised under the amending legislation (Financial Services and Markets Act 2000 (Regulated Activities etc.) (Amendment) (No. 2) Order 2025).

The FCA confirms it is largely implementing the rules and guidance as consulted on, with only minor amendments to ensure the rules and guidance work as intended. Key areas of change include: (i) key product information; (ii) credit reference agency disclosure; (iii) missed payment communications; (iv) debt advice signposting; and (v) the UK Financial Ombudsman Service voluntary jurisdiction. The FCA also concluded some new rules and guidance were needed to clarify its expectations on the application of the consumer duty to deliver its policy objectives. For more information on the changes, please see our blog post "Buy now, pay later – the final furlong... PS26/1 on the regulation of deferred payment credit published".

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The Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2026 have been made and published with an accompanying explanatory memorandum. The statutory instrument (SI) introduces a comprehensive UK regulatory framework for cryptoassets under the Financial Services and Markets Act 2000 (FSMA). This follows the draft version laid before Parliament in December 2025, which we covered previously here. The transitional and savings provisions in the SI enable the FCA to specify a relevant application period and provide for the treatment of, and obligations on, those that do or do not secure all relevant authorisations within that period. This applies to firms seeking authorisation for the first time, FSMA- authorised firms needing to vary permissions, payments and e-money firms, firms that may be accessing the market through section 21 approvers, and firms which are FCA-registered for the purposes of the money laundering regime. The FCA confirmed through its updated webpage that this will be open from 30 September 2026 until 28 February 2027. The provisions enabling the FCA to make or approve rules, guidance, directions etc., in relation to the new regime come into force on 26 February. The go-live date for the new regime is 25 October 2027.

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The Financial Stability Board (FSB) has published its 2026 work programme. The FSB states it will continue its mission to promote global financial stability by addressing systemic financial risks and fostering international cooperation. Key priorities for the year include:

• Vulnerabilities assessments – the FSB will complete a report on private credit and will begin new work on vulnerabilities, possibly including work on foreign exchange derivative markets or private finance.
• Non-bank financial intermediation (NBFI) – the FSB will work to improve its methodologies to assess vulnerabilities in the non-bank sector as well as work on non-bank leverage and over-the-counter derivatives.
• Cross-border payments – the FSB will continue to coordinate the implementation of the G20 cross-border payments roadmap by helping jurisdictions with the development of their voluntary, specific and time-bound action plans.
• Digital innovation and AI – the FSB will continue to monitor developments regarding cryptoassets and will examine issues related to possible stablecoin vulnerabilities. It will also undertake work on sound practices for AI adoption, use and innovation by financial institutions, in close coordination with the standard-setting bodies.

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The Bank of England (BoE) has announced the launch of three new engagement forums under the Retail Payments Infrastructure Board as part of its National Payments Vision, aimed at informing the development of the UK's next generation retail payments ecosystem. The BoE will shortly invite nominations to join the Payments End User Forum, the Payments Innovation Design Group and the Payments Academic Advisory Group, each of which will provide specialist input from consumers and small businesses, innovators and fintechs, as well as academics respectively. Applicants will be assessed on: (i) relevant expertise in the forum's area (end-user insight, payments innovation or academic research); (ii) ability to make time to participate as set out in the terms of reference; (iii) diversity of perspective; and (iv) alignment with the purpose of the specific forum. The initiative is intended to support a more resilient, inclusive and innovative payments landscape by ensuring that system design is shaped by practical user needs, emerging technological opportunities and evidence‑based policy insights.

The European Banking Authority (EBA) has published its draft single programming document (SPD) for 2027–2029, outlining its strategic priorities and resource needs over the three‑year period. The EBA confirms it will focus on implementing new mandates for banking and payments including its oversight role under the Digital Operational Resilience Act, supervision of significant issuers of asset referenced and e money tokens under the Markets in Crypto-Assets Regulation and validation of initial margin models under the amended European Market Infrastructure Regulation (EMIR 3). The EBA will also focus on addressing emerging risks arising from geopolitical instability. This will require new approaches to risk assessment, financial stability monitoring and consumer protection. Supporting EU co legislators also remains central for the EBA as the SPD reflects the priorities for the financial sector and aims to keep the financial system strong while also ensuring it can fund the European economy.

Against this backdrop, the EBA identifies three strategic priorities for 2027–2029: (i) evolving and simplifying the Single Rulebook for banking and financial services; (ii) carrying out risk assessments to support effective risk analysis, supervision and oversight; and (iii) embracing innovation to enhance technological capacity across the sector. The EBA notes that close cooperation with relevant EU and third-country authorities will be required to meet its objectives.

The House of Lords (Financial Services Regulation Committee) has announced the launch of an inquiry into the growth and proposed regulation of stablecoins in the UK. The Committee will examine the development of global and UK stablecoin markets (and its comparison to US and EU markets), expected future growth of sterling‑denominated stablecoins and the opportunities and risks posed to the UK economy, financial services sector, retail consumers and monetary policy. It will also consider the implications of the Bank of England and UK Financial Conduct Authority's proposed regulatory regimes for systemic and non‑systemic stablecoins and whether they are measured and proportionate. A call for evidence, including six questions for written submissions, accompanies the press release. The deadline for responses is 23:59 on 11 March.

The UK Financial Conduct Authority (FCA) has published two separate updated webpages:

• The first updated webpage confirms an extension to the application deadline for those wishing to participate in the stablecoin sprint on 4-5 March and the trade payments roundtable on 15 May. Applications must now be submitted by midnight on 8 February. The FCA will continue to notify applicants of the outcome by 13 February.
• The second updated webpage confirms that the application period for firms wishing to undertake the new cryptoasset regulated activities will be open from 30 September until 28 February 2027.

The European Commission has issued a call for evidence on its forthcoming action plan to combat online fraud committed through the use of technology (whether online or by telephone). The initiative seeks to build on existing frameworks which already establish comprehensive anti-fraud measures, including the Payment Services Directive, the Instant Payments Regulation and the Digital Services Act. The plan aims to reduce the occurrence and impact of online fraud across the EU by reinforcing coordination, enhancing victim support and improving cross-border and multi-stakeholder cooperation. Its primary objective is to establish a more integrated approach to tackling online fraud. This includes strengthening the EU's 'follow-the-money' approach for detecting, tracing and disrupting fraud proceeds that are channelled through payment accounts, e-money and increasingly, crypto-asset transfers, leveraging EU requirements on supplying accompanying information with transfers of funds and certain crypto-assets. The deadline for feedback is 13 February.

The UK Financial Conduct Authority (FCA) has published a second consultation paper (CP26/4) on the application of the FCA handbook for regulated cryptoasset activities. This follows the earlier consultation published in September 2025 (CP25/5) and HM Treasury's draft statutory instrument intended to bring qualifying cryptoasset activities within the scope of the Regulated Activities Order 2001 and under the FCA's remit. The FCA intends to open its authorisation gateway for crypto permissions in September 2026, with the deadline for comments on this consultation being 12 March.

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The UK Financial Conduct Authority (FCA) and the UK Payment Systems Regulator (PSR) have issued a joint prioritisation statement clarifying their enforcement position on the UK Payments Initiative's (UKPI) centralised "access fee" pricing model being developed for commercial variable recurring payments (cVRP). After consulting the Competition Markets Authority (CMA), the regulators confirm that they will not, at this stage, prioritise investigations under Chapter I of the Competition Act 1998 in relation to specific pricing arrangements concerning UKPI's cVRP scheme.

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The UK Financial Conduct Authority (FCA) has published a letter (dated 19 December 2025) to trade associations outlining next steps towards establishing the Future Entity (FE) that will serve as the UK's long‑term open banking standards‑setting body. The FCA reflects on progress made in 2025, noting industry collaboration on the multilateral agreement for variable recurring payments (VRP), the creation of the transitional multilateral agreement operator and associated governance arrangements, continued development of the VRP commercial model and broader industry preparation for the increased adoption of open banking and VRP services.

Looking ahead, the FCA expects 2026 to be a landmark year, with live transactions flowing through the VRP scheme expected in Q1. It also anticipates that HM Treasury will introduce legislation under the Data (Use and Access) Act 2025 (DUAA) granting the FCA new rulemaking powers for open banking. The FCA plans to consult on new rules for the long‑term regulatory framework enabled by these powers. In parallel, the FCA expects industry to establish a body capable of becoming the FE, which it wants to be the UK's primary standards setting body for application programming interfaces (APIs). Subject to legislation, the FCA expects to use its powers under the DUAA to support this objective.

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The UK Financial Conduct Authority (FCA) has announced the launch of a two-day stablecoin tech-sprint. The sprint, taking place on 4-5 March, will explore the use cases for stablecoins in domestic and international payments, covering retail and wholesale applications. A separate, smaller roundtable will take place on 15 May, focusing on use cases for stablecoins in trade payments, identifying risks, opportunities and where regulation would be beneficial. Follow-up roundtables are expected throughout 2026. Outputs from the sprint are expected to provide actionable insights to directly inform future FCA policy decisions on potential stablecoin payment regulation in the UK. The FCA invites participation from fintechs, payment institutions (including EMIs and acquirers), banks, technology providers, corporates, issuers, consultants and representative groups. A participation pack has been made available with more information on the format of the event and the problem statements the FCA expects to tackle. Applications are due by midnight on 4 February. The FCA will notify applicants by 13 February if they have secured a place at the sprint and/or roundtable.

HM Treasury has published a statement from the G7 Cyber Expert Group (CEG) setting out a high‑level, non‑binding roadmap for a coordinated financial‑sector transition to post‑quantum cryptography (PQC). Building on its previous 2024 statement, the CEG highlights while quantum computing promises significant new capabilities for financial services, these advanced computers will be capable of breaking widely-used cryptographic protocols that protect systems and data. Therefore, the CEG explains how the financial sector should start preparing for this in advance of risks. The roadmap outlines a phased approach for both financial sector entities and public authorities for planning and coordination. It highlights key migration activities including awareness and preparation, discovery and inventory, risk assessment and planning, migration execution, testing and ongoing validation and monitoring. Although not legally binding, the CEG encourages firms to begin planning now. It notes that many jurisdictions currently reference 2035 as an overall target for full migration, with the most important systems ideally upgraded earlier (around 2030–2032). While the trajectory of quantum computing development is uncertain, the statement conveys it may be helpful for organisations to establish comparable migration timelines to ensure their milestones can be achieved prior to the availability of cryptographically relevant quantum computers. The CEG further encourages ongoing monitoring, cross sector information sharing and close coordination with international standard setting bodies to support a harmonised transition to PQC.

The UK Payment Systems Regulator (PSR) has published consultation paper CP25/3, proposing specific draft directions to implement two remedies arising from its market review of card scheme and processing fees. The review identified rising fees, weak competitive constraints and insufficient transparency for acquirers and merchants. Following feedback on its April consultation, which proposed four potential remedies, the PSR is now taking forward the following two:

• Information, transparency and complexity remedy, ensuring that acquirers and merchants through their contractual relationship, receive better information to understand the fees they are charged.
• Pricing governance remedy, ensuring that there is evidence behind pricing decisions.

The draft directions have been published separately on this webpage. A draft direction for a third remedy on regulatory financial reporting, intended to give the PSR enhanced data on profitability and card-scheme financial performance, will be consulted on separately by 31 March. The PSR confirms that other previously proposed remedies will not proceed. The deadline for responses is 5:00pm on 13 February.

The European Banking Authority (EBA), the European Central Bank (ECB), national central banks (NCBs), and national supervisory authorities (NSAs) across the EEA have signed a Memorandum of Understanding (MoU). The MoU aims to enhance cooperation and information sharing to support non-bank payment service providers' (NB-PSPs) access to central bank operated payment systems. The MoU sets out clear principles for collaboration to achieve three clear objectives: (i) to establish cooperation between NSAs and NCBs in the EEA for the exchange of information to support NCBs in their assessment of the compliance of NB-PSPs with requirements for granting access to central bank-operated payment systems in the EU; (ii) to establish procedures in a cross-border scenario for the NCB operating the payment system in the host member state to notify the NSA of the home member state about the NB-PSP' application and the NCB's decision regarding its participation; and (iii) to harmonise the processes and procedures across the EEA for the exchange of information between NSAs and NCBs, to the extent possible, by specifying the types of information to be shared, the timing and means of such exchange.

The European Banking Authority (EBA) has published a letter sent to the European Commission (EC) with the outcome of its EU AI Act mapping exercise. In January 2025, the EBA established a dedicated workstream to map the requirements on high-risk AI systems under the EU AI Act against relevant provisions in EU banking and payments regulation, with a focus on the use of AI for creditworthiness and credit scoring. The EBA confirms that, although the EU AI Act identifies overlaps between some requirements on high-risk AI systems and EU financial sector law and envisages targeted derogations and other ways to address this (such as integration or combination of requirements), it does not envisage such derogations for other requirements on high-risk AI systems (e.g. human oversight, data governance, cybersecurity) which are already widely regulated under EU financial services law.

The EBA highlights that the Digital Operational Resilience Act framework extensively covers the cybersecurity and business continuity requirements set out in the EU AI Act and that the Capital Requirements Regulation and Capital Requirements Directive IV requirements already provide a comprehensive and technology-neutral governance and risk management framework that can be applied to supervising the use of AI tools. The EBA sets out in an annex to its letter, a table identifying how EU financial services law already addresses relevant EU AI Act requirements. The EBA believes the table will be useful to the EC when producing the guidelines under Article 96(1)(e) of the EU AI Act on the interplay between the EU AI Act and EU financial services law and managing any regulatory overlaps.

The UK Financial Conduct Authority (FCA) and the UK Payments Systems Regulator (PSR) have published a joint update on the delivery of commercial variable recurring payments (cVRPs) as part of their open banking work. VRPs are an open banking technology that allow users to securely authorise trusted third parties to manage recurring transactions. The summary report highlights significant progress in 2025, with VRPs now accounting for 16% of open banking transactions, with much of the growth occurring through 'sweeping VRPs'. The FCA has been working with industry to advance VRPs for broader commercial use, in line with the National Payments Vision to build a competitive UK open banking market and accelerate rollout to 'phase 1' use cases. This year, 31 firms came together to establish a new UK Payments Initiative (UKPI) to drive VRP adoption for 'phase 1' use cases, including utilities, financial services, and government payments. Market momentum is growing, with additional players developing VRP schemes and transaction testing already in progress. In relation to UKPI, industry has agreed on a first-phase commercial model and the FCA expects the first live payments under the UKPI scheme will take place in the first quarter of 2026.

By the end of 2026, the FCA will assess industry-led cVRP growth and incorporate lessons from phase 1 into a long-term regulatory framework, developed in collaboration with HM Treasury (HMT). HMT is expected to introduce legislation in 2026 granting the FCA new powers to set open banking rules, and the FCA intends to consult on new rules for the long-term regulatory framework before the end of the year. The framework will be the foundation for expanding cVRPs into e-commerce and wider use cases.

The UK Financial Conduct Authority (FCA) and UK Payments Systems Regulator (PSR) have issued a joint letter to HM Treasury (HMT) (dated 11 November) providing an update on their progress against the 2024 recommendations HMT set for payments regulation and outlining focus areas through to 2026.

Key forward-looking priorities include:

• Co-ordination - the regulators set out how they have been working in an increasingly collaborative way to ease congestion in payments regulation.
• Open banking and open finance – the FCA has established a new department incorporating FCA and PSR capabilities, replacing the Joint Regulatory Oversight Committee (JROC) and streamlining decision-making for open banking and open finance. The FCA is working with industry to establish a future entity for open banking ahead of developing the statutory instrument with HMT and subsequently the long-term regulatory framework for open banking. In addition, the FCA has launched the smart data accelerator, with applications currently open for two prioritised open finance use cases in SME lending and mortgages. The FCA will publish a roadmap for this in early 2026, with regulatory foundations in place during 2027. The FCA is also collaborating with the Department for Business and Trade on cross-sector data sharing.

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The European Banking Authority (EBA) and the European Central bank (ECB) have published their joint 2025 report examining payment fraud trends across the EU/EEA from H1 2022 to H2 2024. The report confirms that strong customer authentication (SCA), mandated under the revised Payment Services Directive since 2020, remains effective in reducing fraud, particularly for card payments. However, overall fraud losses rose to EUR4.2 billion in 2024 (up from EUR3.5bn in 2023). Credit transfer fraud accounted for EUR2.2bn, while card payment fraud reached EUR1.3bn, with losses significantly higher for transactions outside the EEA where SCA is not required. The EBA and ECB stress the need for adaptive security measures and continued monitoring to address evolving fraud risks. For more information, you may like to read our blog post "Key takeaways from the EBA and ECB joint 2025 report on payment fraud".

The UK National Audit Office (NAO) has published its report on the Bank of England's (BoE) Real-Time Gross Settlement (RTGS) renewal programme. The RTGS is a core part of the UK's financial infrastructure, and the Bank of England launched the renewed system in April. The report, accompanied by a summary, examines whether the BoE managed the programme effectively to achieve a new system resilient to future developments and risks, and whether it identified wider learning from the programme. The NAO concludes that the BoE demonstrated good practice in digital transformation and risk management, with delays limited to 18 months and cost increases deemed reasonable given the programme's complexity. With the new RTGS now operational, the BoE plans to improve functionality over the next two to three years and will need to set long-term priorities to maintain and improve the system.

The NAO recommends the BoE:

• Applies lessons learned across other digital and business transformation projects.
• Sets clear plans for ongoing investment and resourcing to keep the RTGS and supporting services up to date.
• Understands and manages the impact of higher levels of change on RTGS users.
• Assesses the effectiveness of its interventions to widen access and reduce barriers, ensuring the best mix is in place.

The European Banking Authority (EBA) has published a single rulebook Q&A relating to the revised Payment Services Directive (PSD2). The Q&A addresses whether, under Article 68(1) of PSD2, a payment service provider (PSP) may impose general spending limits, daily or per transaction, for payment transactions initiated through specific channels (e.g., mobile banking) to mitigate fraud risk. The question also explores whether PSPs can apply different limits for domestic versus cross-border payments within the EU and whether PSPs are obliged to increase such limits upon a payment service user's (PSU) request for regular credit transfers. Additionally, the query considers the interaction between PSD2 and the Instant Payments Regulation (EU) 2024/886, particularly regarding PSU rights to set or modify limits for instant credit transfers in euro.

The Financial Services Regulatory Initiatives Forum has published the ninth edition of the Regulatory Initiatives Grid. This sets out the regulatory pipeline for the next two years, outlining 124 live initiatives which is a 13% reduction since the last grid was published. Key priorities include implementing Basel 3.1 standards, advancing the strong and simple prudential framework and reforms to the prospectus regime and wholesale markets review. Innovation-focused measures cover stablecoin regulation, the national payments vision, and development of a UK captive insurance regime, while consumer-focused reforms include the advice guidance boundary review and regulation of buy now pay later products. The Grid also highlights efforts to streamline regulatory processes, with 45 joint initiatives across sectors, and provides indicative timelines for consultations and implementation through 2027. Separate press releases announcing the Grid have also been published by the UK Financial Conduct Authority and the Bank of England.

The UK Financial Conduct Authority (FCA) has sent a letter to the Prime Minister providing an update on its growth strategy. It confirms delivery of most of the 50 pro-growth measures announced in January and outlines plans for 2026. The plans include finalising rules on stablecoins, setting out the delivery plan for open finance, reforming rules for venture capital and alternative investment fund managers and further speeding up IPO applications. The FCA also cites its plans to further overhaul mortgage rules so more people get on the housing ladder and is preparing for its expanded remit as anti-money laundering supervisor and integration of the UK Payments Systems Regulator. The letter highlights active support for firms digitising, with 31 already testing AI use cases, and commits to enabling tokenisation in asset management to drive efficiency and competition. The FCA also urges swift progress on digital ID to streamline know your customer requirements and calls for faster legislation to maintain reform momentum, including modernising the Consumer Credit Act. Finally, the FCA will use its convening power to galvanise system-wide responses to cross-cutting issues such as financial inclusion and mobilising defence investment to protect national and economic security.

The European Banking Authority (EBA) has published a follow-up peer review report on the authorisation of payment institutions (PIs) and electronic money institutions (EMIs) under the revised Payment Services Directive (PSD2). The review assessed actions taken by 29 national competent authorities (NCAs) following the 2023 report to address recommendations on authorisation processes, implementation of the EBA guidelines on authorisation, governance, AML/CFT controls, and local substance. While most NCAs improved efficiency through clearer guidance, pre-application engagement, and streamlined procedures, authorisation timelines remain highly divergent, ranging from 4-6 months to 27 months in one member state, with a median of 9.5 months (counting from the date of submission of an application). Delays are attributed to incomplete or low-quality applications and the time applicants take to address deficiencies.

While several supervisors have addressed previously identified deficiencies in the implementation of the EBA guidelines, notably on business plan assessments and AML/CFT controls, some gaps remain and in the assessment of local substance, creating risks of regulatory arbitrage. Therefore, despite notable improvements and a general move towards convergence, further efforts are needed. The EBA calls for further convergence to ensure a level playing field and robust supervisory practices across the EU.

The European Commission (EC) has published a Communication to the European Parliament, the European Council, the Council, the European Central Bank, the European Economic and Social Committee and the Committee of the Regions on further development of capital market integration and supervision within the Union, announcing a set of major legislative reforms. The package seeks to address obstacles to innovation and barriers to integration resulting from divergent rules, duplicative requirements and inconsistent supervision. The EC proposes a suite of amendments to key EU financial services and capital markets legislation in a package described as a central component of the savings and investments union (SIU), specifically a:

• Regulation which will amend: (i) the European Securities and Markets Authority (ESMA) Regulation; (ii) the European Markets Infrastructure Regulation (EMIR); (iii) the Markets in Financial Instruments Regulation (MIFIR); (iv) the Central Securities Depositories Regulation (CSDR); (v) the Distributed Ledger technology Pilot Regulation (DLTPR); (vi) the Markets in cryptoasset Regulation (MiCAR); and (vi) the Cross-Border Distribution of Funds Regulation (CBDR). It also includes targeted amendments, in line with the changes proposed to the ESMA regulation aimed at making EU supervision more efficient, to: (a) the Central Counterparties Recovery and Resolution Regulation (CCPRRR); (b) the Securities Financing Transactions Regulation (SFTR); (c) the Credit Ratings Agency Regulation (CRAR); (d) the Benchmark Regulation (BMR); (e) the simple, transparent and standardised (STS) securitisation Regulation; (f) the European Green Bond Regulation (EuGB Regulation); (g) the Environmental, Social and Governance (ESG) rating Regulation.

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The UK Financial Conduct Authority (FCA) has published an update on its forthcoming review of the access to cash regime. The regime, introduced under the Financial Services and Markets Act 2023, seeks to maintain responsible provision of cash access services to consumers and businesses. The FCA expects to begin its review in Q4 2026 and publish findings in Q2 2027. While the exact scope and methodology will be determined closer to the time, the review will assess compliance, costs to firms and the regime's effectiveness in preventing gaps in cash access. It will include quantitative analysis and evaluation of indicators such as consumer sentiment and cash coverage data, alongside stakeholder engagement.

The Council of the EU and the European Parliament have announced a provisional political agreement on the EU payments package. While the final texts of the third Payment Services Directive (PSD3) and the Payment Services Regulation (PSR) are not yet available, press releases indicate that negotiations centred on three key areas: fraud prevention, transparency and open banking. For further details, you may like to read our blog post "European Council and Parliament reach provisional agreement on EU Payments Package".

The UK Financial Conduct Authority (FCA) has published a new webpage announcing the launch of a special stablecoins cohort within its Regulatory Sandbox for firms issuing stablecoins. This will enable UK firms planning to issue stablecoins to test products under the UK's evolving regulatory regime. The cohort supports innovation in financial services and complements projects such as the Digital Securities Sandbox. For a successful application, firms must demonstrate: (i) clear readiness to begin testing; (ii) hold appropriate permissions and resources; (iii) prepare a well-aligned test plan consistent with the recent FCA stablecoin issuance consultation paper CP25/14; and (iv) include as much detail as possible. Applications close on 18 January 2026. Successful participants will be notified by the FCA, and feedback will be provided to unsuccessful applicants.

The European Banking Authority (EBA) has published a fact sheet summarising the findings from its 2025 mapping exercise on the interaction between the EU AI Act (Regulation EU 2024/1689) and existing banking and payments legislation. This includes the Capital Requirements Regulation (575/2013), the Consumer Credit Directive (2008/48/EC), the Mortgage Credit Directive (2014/17/EU) and the Payment Services Directive ((EU) 2015/2366). The EBA's key findings include: (i) no significant contradictions have been found between the AI Act and EU banking and payment legislation; (ii) the AI Act is complementary to EU banking and payment sector legislation, which already provides a comprehensive framework to manage risks. However, some efforts may be required by banks and other financial institutions to integrate the two frameworks effectively; and (iii) the co-existence of multiple authorities supervising financial entities' compliance highlights the importance of supervisory cooperation to ensure effective implementation of the AI Act.

The EBA also concludes that no immediate changes to its guidelines or new EBA guidelines are planned. Instead, the EBA will follow up with actions to contribute to a common supervisory approach to supervisory cooperation and implementation of sectoral requirements alongside AI Act requirements. The EBA will undertake specific activities in 2026–2027 to support the implementation of the AI Act in the EU banking and payments sector by: promoting common supervisory approaches and cooperation among national competent authorities responsible for financial sector supervision and market surveillance authorities; and providing input to the AI office, as appropriate, and participating in discussions of the AI Board Subgroup on Financial Services.

The UK Payments System Regulator (PSR) has published a compliance report on Specific Direction 17 which mandated the implementation of its name checking service, Confirmation of Payee (CoP), by UK payment service providers (PSPs) to prevent misdirected and fraudulent payments. PSPs were divided into two groups subject to different implementation timelines: Group 1 PSPs were required to implement CoP by 31 October 2023; and Group 2 PSPs by 31 October 2024. The report shows compliance is strong, with over 320 organisations now offering CoP checks. While most firms have met deadlines, the PSR opened enforcement investigations into a few non-compliant PSPs, including three Group 2 firms that missed the deadline and one ongoing case from Group 1. Directed firms are reminded of their obligations under General Direction 1 to maintain transparency regarding a PSPs ability to comply with PSR requirements, proactively communicate with the PSR if deadlines are missed or expected to be missed, plan regulatory changes early and ensure compliance before launching new services.

The Financial Stability Board (FSB) has published a letter from the FSB's Chair, Andrew Bailey, addressed to G20 leaders. The letter urges G20 leaders to accelerate efforts to modernise financial regulation while safeguarding stability, citing significant gaps in reform implementation and a challenging economic outlook. The next phase of the FSB's work will look deeper into where full, timely and consistent implementation of global standards, such as Basel III, was not achieved.

The letter highlights the growing influence of non-bank financial intermediaries in global financial markets, now estimated at USD2 trillion globally, and stresses the need for robust monitoring to prevent systemic risks. It also calls for continued attention to national policy barriers to achieve the objectives of the G20 Roadmap for enhancing cross-border payments. With the rise of digital assets, the FSB calls on authorities to carefully consider how frameworks are designed to ensure they are effective, consistent, and supportive of safe innovation and notes that it will be equally important to consider how stablecoins can operate effectively and safely across borders. The FSB's work programme for the year ahead will include a focus on stablecoins and other forms of payment.

The Investment Association and the Investment Management Association of Singapore, in partnership with the UK Financial Conduct Authority (FCA) and Monetary Authority of Singapore (MAS), have released a joint report on challenges and opportunities in tokenised asset markets across the UK and Singapore. The report highlights an "adoption gap" between innovation in digital assets and investor requirements. It introduces a practical operational readiness checklist in section 4, to guide market participants looking to design and launch tokenised financial products.

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The Bank of England (BoE) has published a consultation paper outlining its proposed regulatory framework for sterling-denominated systemic stablecoins. Under the framework, HM Treasury (HMT) will determine which payment systems using stablecoins, and their service providers, are recognised as systemically important. Once designated, these entities will fall within the BoE's remit and be subject to its powers under the Banking Act 2009. The proposed regime does not cover stablecoins used for non-systemic purposes which are not widely used by individuals to make retail or business payments. These activities will remain under the supervision of the UK Financial Conduct Authority (FCA).The consultation builds on feedback to the 2023 discussion paper.

Key proposals include:

• Allowing issuers to hold up to 60% of backing assets in short-term sterling-denominated UK government debt, with the remaining 40% as unremunerated deposits at the BoE. Issuers deemed systemic at launch, or transitioning from the FCA regime, may initially hold up to 95% in short-term UK government debt to support viability during growth.

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The Payments Vision Delivery Committee (PVDC) has published its long-term strategy for the future UK retail payments infrastructure, building on the government's National Payments Vision. The PVDC, comprising HM Treasury, the Bank of England, the UK Financial Conduct Authority (FCA) and the UK Payments Systems Regulator, developed the strategy following the Mansion House 2025 announcement of a new model of public and private sector collaboration.

With user needs at its core, the strategy focuses on five high-level strategic outcomes: (i) greater choice of innovative, cost-effective payment options that meet consumers and business needs; (ii) interoperability across a multi-money ecosystem, including new and existing forms of digital money; (iii) strong protections against fraud and financial crime; (iv) fair, transparent and non-discriminatory access for participants to drive competition and innovation; and (v) operational and financial resilience of the payments ecosystem.

Governance and delivery oversight will be led by the newly established Retail Payments Infrastructure Board, alongside an industry-led Delivery Company responsible for implementing the design. Implementation is expected to span several years. The FCA confirms in a statement which has been published on the same day that the strategy will be followed by the "Payments Forward Plan", which will be a sequenced plan of future payments initiatives.

The BIS Committee on Payments and Market Infrastructures (CPMI) and the International Organization of Securities Commissions (IOSCO) have published two reports addressing financial market infrastructures' (FMIs) management of general business risks and losses.

The Level 3 assessment report reviews compliance with PFMI Principle 15 ("general business risk") across 34 FMIs based on work carried out in 2023–24. The report identifies six significant concerns highlighting clear challenges for FMIs' resilience to different types of risk that could result in general business losses. These include: (i) failure to consider general business risk when determining liquid net assets funded by equity (LNAFE); (ii) insufficient resources for recovery and wind-down plans; (iii) lack of additional LNAFE beyond participant default coverage; (iv) absence of recovery plans; (v) gaps in orderly wind-down planning; and (vi) no explicit plan for raising additional equity in case of capital shortfalls. In response, the CPMI and IOSCO has issued a consultative report proposing supplemental guidance to the PFMI. The guidance does not introduce new standards but elaborates on the existing PFMI principles. It clarifies the scope of general business risk and its interaction with other principles, and provides guidance on identifying, monitoring and managing general business risks; determining the minimum amount of LNAFE; and governance and transparency. The guidance also considers the findings from the Level 3 assessment report. The deadline for comments is 6 February 2026.

HM Treasury (HMT) has released its financial inclusion strategy, outlining a comprehensive national plan to remove barriers to financial participation and to build financial resilience. The strategy focuses on six main areas: (i) improving digital inclusion and access to banking through the roll-out of 350 in-person banking hubs and the launch of a pilot scheme enabling the opening of a bank account without standard ID; (ii) supporting savings by delivering regulatory clarity to enable employers to offer workplace savings schemes with confidence and driving uptake of the government's Help to Save scheme; (iii) ensuring the insurance market is supporting the financial wellbeing of households and vulnerable customers; (iv) increasing access to affordable credit; (v) strengthening debt advice provision; and (vi) introducing compulsory financial education in primary schools. HMT will review the strategy's implementation progress two years after publication and provide an update thereafter.

The Financial Services and Markets Act 2000 (Regulated Activities etc.) (Amendment) (No. 2) Order 2025 has been laid before Parliament, accompanied by an explanatory memorandum. A draft was laid before Parliament in June. The Order amends the Financial Services and Markets Act 2000 (Regulated Activities etc.) (Amendment) Order 2025 (the 2025 Order) which provides for certain buy-now-pay-later (BNPL) agreements to become "regulated deferred payment credit agreements" with effect from 15 July 2026. Under article 3(2) of the 2025 Order, nearly all merchants brokering BNPL products are exempt from the regulatory requirements concerning credit broking by virtue of a new provision (article 36FB) in the Financial Services and Markets Act 2000 (Regulated Activities) Order 2001 (RAO). Generally, merchants who introduce customers to regulated credit products are undertaking the regulated activity of credit broking under article 36A of the RAO and must have regulatory approval, unless an exemption applies.

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The European Parliament's Committee on Economic and Monetary Affairs (ECON) has published three draft reports proposing amendments to the European Commission's legislative package on the establishment of the digital euro. These proposals collectively aim to establish a comprehensive legal framework for the issuance, use and coexistence of the digital euro alongside physical cash. The first draft report (COM(2023)0369) proposes amendments to the proposed regulation establishing the digital euro as a central bank digital currency, detailing its governance and operational principles. Accompanying this, the second draft report (COM(2023)0368) proposes limited procedural amendments to the proposed regulation on the provision of digital euro services by payment service providers in Member States whose currency is not the euro. Finally, the third draft report (COM(2023)0364) proposes amendments to the proposed regulation on the legal tender status of euro banknotes and coins. This measure is designed to safeguard the mandatory acceptance of continued use of cash, ensuring it remains a viable payment option alongside the digital euro.

The European Central Bank Governing Council has announced its decision to move on to the next phase of the digital euro project in a letter to Aurore Lalucq, Chair of the European Parliament's ECON Committee. The announcement follows the successful completion of the two-year preparation phase launched in 2023, which laid the groundwork for issuing a digital euro. The digital euro is intended to complement cash by offering a secure, inclusive and resilient public digital payment solution across the euro area. The ECB states the final decision on whether to issue a digital euro, and when, will only be made once the relevant legislation has been adopted, which is expected by 2026. A pilot exercise and initial transactions could begin as early as mid-2027, with the ECB aiming to be technically prepared for a potential first issuance by 2029. Published alongside the announcement were: (i) a report on digital euro user research; (ii) a technical report focusing on the workstream led by the dedicated Euro Retail Payments Board; and (iii) an update from the Rulebook Development Group on the digital euro scheme.

The Bank of England (BoE) has published an update on the ongoing design phase of the digital pound, a proposed form of central bank digital currency intended to complement existing payment methods. While no decision has yet been made on its introduction, the focus over the past year has been on developing a detailed blueprint, supported by design notes and practical experimentation through the Digital Pound Lab. The blueprint is expected to be published in 2026.

This work aims to deepen understanding of how public money could operate within a multi-money system and will inform a joint, evidence-based assessment by the BoE and HM Treasury in 2026. In parallel, payment trends in the UK and internationally will continue to be monitored to support this assessment. If a decision is made to proceed, a digital pound would only be introduced following the passage of primary legislation by the UK Parliament. The BoE will continue targeted experiments and stakeholder engagement to explore what is viable and what may need to change.

The UK Financial Conduct Authority (FCA) and the UK Payment Systems Regulator (PSR) have published a joint response to HM Treasury's consultation on consolidating the PSR's functions within the FCA's legislative framework. Both regulators support the proposed integration, agreeing with the overarching approach to the consolidation, and believe that the proposed model enables a coherent and holistic view of regulatory issues that impact payment systems and payment services. Their response outlines work already completed as well as ongoing efforts to prepare for the transition. In terms of next steps, beyond development of the detailed legislation, and in the longer term, they consider that there may be aspects of the FSMA regime that may be appropriately adapted to payment systems regulation. There may also be further opportunities to review how the developing regime for the regulation of activities involving stablecoins or other crypto-assets fits together with the regulation of systems that use such technology to transfer funds. In the accompanying annex, the PSR and FCA set out their responses to the specific consultation questions. You may also like to read our opinion piece "UK Payment Systems Regulator to be abolished - what's next?" which explores key considerations and potential impact of the transition of the consolidation.

The UK Financial Conduct Authority (FCA) has published its findings from a multi-firm review assessing how UK payment service providers (PSPs) (including banks and other businesses offering payment accounts) detect and respond to romance fraud, a growing financial crime where victims are deceived into sending money to fraudsters who engineer false romantic relationships or friendships. The review covered 60 cases across six firms and the conclusions highlight examples of good practice and areas for improvement. Whilst some firms are leading the way with proactive engagement and compassionate support reflecting best practice, these examples were not consistent across the industry and it is clear that staff play a critical role in interventions. Equally, the review also examined the effectiveness of firms' systems and controls in detecting romance fraud, to avoid missed opportunities to detect suspicious activity, including transactions to overseas jurisdictions, multiple payments over a short period and sudden increases in the value of funds being sent.

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The Bank of England (BoE) has published the terms of participation for its upcoming Synchronisation Lab which will support the testing and refinement of a proposed synchronisation capability for the UK's renewed Real-Time Gross Settlement (RTGS) service, RT2. Synchronisation would allow for atomic settlement in central bank money: the conditional settlement of funds in RT2 against assets on a variety of external asset ledgers, meaning that funds in RT2 will settle if and only if the external asset also settles. The Lab is being launched as a platform to simulate the synchronisation interface enabling prospective synchronisation operators (Lab Participants), to develop and demonstrate viable propositions across multiple use cases.

The Lab is scheduled to launch in Spring 2026 and will run for approximately six months across four six-week testing and development phases. In each phase, Lab Participants will showcase end-to-end synchronised transaction flows and interact with synchronisation users. Lab findings will inform the design and delivery of a potential future live RT2 synchronisation capability. Participation is by invitation by the BoE and based on an application process. Technical onboarding will begin roughly one month before launch. Demonstrations and a final report summarising key learnings will follow the Lab's conclusion.

The European Banking Authority (EBA) has published a report on white labelling, accompanied by a fact sheet. In the report, the EBA considers the use of white labelling as a business model by the firms that are under its mandate, including credit institutions, e-money institutions, payment institutions, non-bank issuers of asset-referenced tokens and non-bank lenders. The report defines white labelling as a business model in which a financial institution (the provider) enters into an agreement with another entity (the partner, who may or may not be a financial institution) to distribute and offer one or more financial products and services under the partner's own brand only. The EBA finds that white labelling is being widely used, with 35% of surveyed banks employing the model to distribute a broad range of financial products and services, both domestically and cross-border, including account and payment services, credit provisioning and open banking services.

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The UK Payment Systems Regulator (PSR) has published consultation paper MR22/2.8 on a methodology for developing a price cap on multilateral interchange fees (MIFs) for UK-EEA card-not-present (CNP) outbound transactions. The PSR's 2024 final report found that interchange fees on UK-EEA CNP outbound transactions had increased to unduly high levels and were detrimental to UK merchants and consumers. The PSR proposes using the Merchant Indifference Test (MIT) as a starting point. The MIT assesses whether a merchant would refuse a card payment if they were certain that a customer who was about to pay at the cash register had an alternative means to pay. The test is passed if accepting the card does not increase the merchant's operating costs, therefore making the merchant indifferent between a card transaction and one using the alternative payment method. The PSR will decide on an appropriate cap based on the results of the MIT and on evidence of the impact of interchange fees on issuers' incentives and on competition between methods of payment.

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The Financial Stability Board (FSB) has published its consolidated progress report on the G20 Roadmap for Enhancing Cross-Border Payments. While notable policy milestones have been achieved since the roadmap's launch in 2020, the report highlights that these efforts have yet to yield meaningful improvements for end-users globally. Key performance indicators for 2025 show only a slight improvement since 2023, with improvements in the speed of wholesale payments and remittances, but challenges persist in cost reduction and transparency of information to end-users. The FSB notes it is unlikely for the global roadmap's targets to be met by 2027. The focus for the coming year will be on strengthening monitoring and supporting implementation of the international policies agreed under the G20 roadmap.