News & Analysis as of

Payment Systems United Kingdom

Walkers

The case for payment regulations in the Crown Dependencies

Walkers on

Payments was historically a hidden component of financial services only fully understood by specialists. In the last 20 years, however, it has become a strategic differentiator not just between banks but also between...more

Hogan Lovells

Payments and e-money: UK FCA publishes policy statement on changes to safeguarding regime

Hogan Lovells on

The FCA believes that some payments firms do not currently have sufficiently robust safeguarding practices. This poses a risk of harm to consumer and market integrity that the FCA is seeking to mitigate. ...more

A&O Shearman

UK PSR Revokes Specific Directions 2, 2a, 4, and 4a

A&O Shearman on

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...more

A&O Shearman

FCA Publishes Changes to the Safeguarding Regime for Payments and E-money Firms

A&O Shearman on

The FCA 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...more

Orrick, Herrington & Sutcliffe LLP

UK Financial Conduct Authority issues feedback on the new standard-setting body for open banking

On August 8, the Financial Conduct Authority (FCA) published feedback on the creation of the primary regulator for open banking, the “Future Entity.” The Future Entity will establish and oversee core standards, including API...more

A&O Shearman

BoE consults on extending RT2 and CHAPS settlement hours – Phase 1

A&O Shearman on

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...more

Hogan Lovells

Bank of England consults on longer RTGS and CHAPS operating hours

Hogan Lovells on

The Bank of England (the “Bank”) published a consultation paper (“CP”) on 29 July 2025 on proposals to extend Real-Time Gross Settlement (“RTGS”) and CHAPS operating hours. The CP follows the Bank’s 2024 discussion paper on...more

A&O Shearman

UK FCA consults on BNPL rules for 15 July 2026

A&O Shearman on

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...more

A&O Shearman

BoE publishes fundamental rules for FMIs

A&O Shearman on

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...more

A&O Shearman

PSR publishes regulatory fees figures for 2025/26

A&O Shearman on

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...more

A&O Shearman

HMT publishes latest NRA of money laundering and terrorist financing risks

A&O Shearman on

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...more

A&O Shearman

Mansion House: HMT and BoE announce plans for new UK retail payments model under NPV

A&O Shearman on

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...more

A&O Shearman

Mansion House: HMT policy paper on wholesale financial markets digital strategy

A&O Shearman on

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...more

Hogan Lovells

The Payments Newsletter including Digital Assets & Blockchain, July 2025

Hogan Lovells on

Key developments of interest over the last month include: the UK government's communications in connection with the Chancellor's annual Mansion House speech, and the launch of its Financial Services Growth and Competitiveness...more

A&O Shearman

BNPL UK statutory instrument partially in force

A&O Shearman on

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...more

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

A&O Shearman on

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

A&O Shearman on

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

A&O Shearman on

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

A&O Shearman on

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

A&O Shearman on

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

Venable LLP on

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

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