News & Analysis as of

Payment Systems United Kingdom

A&O Shearman

UK APPG publishes report assessing the APP fraud mandatory reimbursement requirement

A&O Shearman on

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...more

A&O Shearman

PSR consults on the revocation of SD4

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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...more

A&O Shearman

FCA findings on risk and wind-down planning in payment and e-money firms

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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...more

Hogan Lovells

Bank of England: an update on the digitalisation of finance

Hogan Lovells on

On 2 July 2025, the Bank of England published a speech delivered by Sasha Mills (Executive Director, Financial Market Infrastructure) at City Week 2025. The speech signals the Bank's support for the digitalisation of...more

A&O Shearman

UK regulators publish updated MoU on payment systems

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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...more

A&O Shearman

HMT updates BNPL policy for domestic premises suppliers

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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...more

A&O Shearman

The Payment Services and Payment Accounts (Contract Termination) (Amendment) Regulations 2025

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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...more

Venable LLP

FTC Targets “Merchant of Record” for Unlawful Payment Processing, TSR, and ROSCA Violations

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In a development that underscores the Federal Trade Commission’s (FTC) growing scrutiny of the “merchant of record” model, the commission announced a $5 million settlement with UK-based Paddle.com Market Limited (Paddle),...more

Ropes & Gray LLP

FCA Extends Investment Research Payment Optionality to Fund Managers

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Last month the Financial Conduct Authority (FCA) set out its final rules related to the application of investment research payment optionality to fund managers. This move follows its consultation paper late last year which...more

A&O Shearman

PSR consolidated policy statement on APP scams reimbursement requirement

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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...more

A&O Shearman

UK Government advances BNPL Regulation

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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)...more

A&O Shearman

PSR update on impact of APP fraud reimbursement scheme

A&O Shearman on

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...more

Hogan Lovells

The Payments Newsletter including Digital Assets & Blockchain, May 2025

Hogan Lovells on

Key developments of interest over the last month include: draft legislation to regulate BNPL credit in the UK (in contrast to the de-prioritising of enforcement of BNPL regulatory breaches in the US); final confirmation of UK...more

A&O Shearman

FCA policy statement on investment research payment optionality for fund managers

A&O Shearman on

The UK Financial Conduct Authority (FCA) has published a final policy statement (PS25/4), together with an updated webpage and press release, on final rules extending the new payment optionality for investment research to...more

A&O Shearman

BoE speech on the digitalisation of money and assets: proposed stablecoin regulatory framework

A&O Shearman on

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...more

Hogan Lovells

UK: A new litigation risk for PSPs? Quincecare claim brought by derivative action is successful

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Ever since the Supreme Court held, in Philipp v Barclays Bank plc1(Philipp), that claims based on the Quincecare duty against the payment services provider (PSP) which paid the funds away were not open to victims of...more

A&O Shearman

HMT announces new rules for bank account closures and payment service terminations

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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...more

Hogan Lovells

UK payment services: final rules limiting rights for PSPs to exit customer relationships laid before Parliament

Hogan Lovells on

While recent announcements have focussed on the government’s growth agenda, HM Treasury (HMT) has also now pressed ahead with publishing final draft regulations limiting the rights for banks and other payment service...more

A&O Shearman

FCA findings on international payment pricing transparency

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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...more

A&O Shearman

PSR annual plan and budget

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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...more

Hogan Lovells

Consumer Duty: UK FCA raises the bar for international payment pricing transparency

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The FCA has published the findings from its review of firms’ approach to pricing transparency when offering UK customers international money remittance and cross border payments. It highlights proactive and clear disclosure...more

Hogan Lovells

The Payments Newsletter including Digital Assets & Blockchain, April 2025

Hogan Lovells on

Key developments of interest over the last month include: the Central Bank of Somalia announcing the launch of the Somalia Instant Payment System (SIPS), the country’s first nationwide instant payments infrastructure; the...more

A&O Shearman

UK 2025 Regulatory Initiatives Grid published

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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...more

A&O Shearman

BoE reports on digital pound developments and implementation

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The Bank of England (BoE) has published a series of documents regarding its work on implementing the digital pound. The Digital Pound Experiment Report on Offline Payments assesses the technical feasibility of implementing an...more

A&O Shearman

UK PSR delays APP scams claims management consultation

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The Payment Systems Regulator (PSR) has published an update regarding next steps for its claims management consultation and its intention to adopt reporting standard B by December 2026. The claims management consultation was...more

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