UK FCA and PSR's joint reprioritisation statement on UKPI's cVRP scheme

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.

The pricing arrangements addressed by this prioritisation statement relate only to Phase 1/Wave 1 of UKPI's cVRP scheme. Phase 1/Wave 1 relates to limited types of payment use cases known as "lower risk" use cases. This statement is intended to apply for the period of time ahead of implementation of the legislative framework under the Data (Use and Access) Act 2025 (DUAA) expected by the end of 2026 or until July 2027, whichever is earlier. In the event that the legislative framework is not implemented by July 2027, the FCA and the PSR will consider whether it would be appropriate to issue a further non-prioritisation statement to cover the pricing arrangements outlined in the statement—if so, the content and form will be decided at the time, taking into account developments in the market. As stated in their cVRP December update, the FCA and PSR will continue to monitor and engage on the development of these arrangements, the Phase 2/Wave 2 commercial model and cVRP schemes more generally. The statement does not prevent the FCA or PSR from opening an investigation in the future if the FCA and/or PSR receive new information which changes the prioritisation assessment.

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