UK payments regulation, open banking, FCA, PSR, scheme governance
In short: Consumer credit financial promotions are under FCA review. CP26/15, published on 29 April 2026, proposes removing prescriptive rules from CONC 3 and relying on the Consumer Duty consumer understanding outcome, and opens a discussion on representative APR disclosure, including the 51% threshold. Responses are due by 17 June 2026. By Rob Bratby, Managing…
In short: Financial market infrastructure supervision in the UK is split by statute. Section 285A of the Financial Services and Markets Act 2000 makes the FCA the appropriate regulator for recognised investment exchanges and the Bank of England the appropriate regulator for central counterparties and central securities depositories. A Schedule 17A memorandum of understanding, reviewed…
In short: Concurrent competition powers let the FCA, PSR, Ofcom and five other sector regulators apply the Competition Act 1998, not just the CMA. The CMA’s annual concurrency report, published on 2 June 2026, shows that in 2025-26 only two sector regulators ran Competition Act cases, while reform and the PSR-into-FCA merger are about to…
In short: FCA sanctions systems and controls are now a standing supervisory expectation for payment and e-money firms. On 28 May 2026 the FCA published findings from assessing over 150 firms since February 2022, with UK assets reported frozen rising to £37bn in 2024-25. Screening calibration, alert management and asset freezing are the recurring weak…
In short: geographic market definition CMA practice asks where customers would switch if a hypothetical monopolist raised price by 5 to 10 per cent. The CMA’s 21 May 2026 Welltower decision found competition concerns in 30 local catchment areas. The CMA reaches the finding through postcode-level overlap mapping and drive-time isochrone analysis, a methodology that…
In short: Spring 2026 payments reforms are one month into live operation. SI 2025/688 came into force on 28 April 2026, substituting regulation 51 of the PSRs 2017 and inserting regulations 51A to 51D. The FCA’s PS25/12 Supplementary Safeguarding Regime came into force on 7 May 2026. By Rob Bratby, Managing Partner, Bratby Law. 30+…
In short: The Financial Services and Markets Bill 2026 provides for the abolition of the Payment Systems Regulator and the transfer of its functions to the FCA. The Bill is the legal mechanism; the substantive consolidation happens on commencement. For UK payment institutions and e-money institutions, the supervisor changes; the substance of payments regulation does…
In short: Framework contract termination by UK payment service providers operates under a new architecture from 28 April 2026. Closing a customer account opened on or after that date now requires 90 days’ written notice, sufficiently-detailed reasons and Financial Ombudsman Service signposting. Five carve-outs in regulation 51C and a fast-track regime in regulation 51D sit…
In short: The FCA Approach Document version 8 sets the supervisory expectation for the safeguarding regime that took effect on 7 May 2026. UK PSPs and EMIs must operate segregation, daily reconciliation, monthly returns and an annual audit under CASS 15, CASS 10A, SUP 16.14A and SUP 3A. A designated senior individual is accountable for…
In short: Consumer Credit Act reform takes the prescriptive paperwork rules for consumer credit out of the 1974 Act and puts them into the FCA Handbook. Agreement forms, pre-contract disclosure and copies-and-information duties are all in scope. HM Treasury announced this on 18 May 2026. The Financial Services and Markets Bill is the vehicle. The…
In short: FCA work programme 2026 sets out year-two delivery on four strategic priorities and confirms an annual funding requirement of £788.9m for 2026/27. The operational diary covers DPC/BNPL from 15 July 2026, cryptoasset applications from 30 September 2026 with regime go-live in October 2027, fund tokenisation guidance, captive insurance, T+1 settlement preparation, ESG ratings…
In short: DMA in-app payments parity is here to stay. If you sell or process payments inside iPhone or Android apps, the EU rules forcing platforms to allow alternative wallets are locked in. The Commission confirmed that on 28 April 2026. In the UK, Apple and Google signed CMA commitments on 1 April 2026 and…