UK payments regulation, open banking, FCA, PSR, scheme governance
The Court of Justice in Betaal Garant (C-51/25) decided the credit transfer question and nothing else. Money remittance, defined more widely in regulation 2(1) of the PSRs 2017, is where a UK analysis now has to go.
In short: The critical third parties regime brought Amazon Web Services EMEA SARL, Google Cloud EMEA Limited, Microsoft Ireland Operations Limited and Oracle Corporation UK Limited under FCA, PRA and Bank of England oversight on 13 July 2026, under SI 2026/777 and Chapter 3C of FSMA 2000. The UK regime binds providers with rules and…
In short: agentic payments liability is largely governed by the Payment Services Regulations 2017. Whether the payer consented under regulation 67 determines whether the provider must refund under regulation 76, and regulation 75 puts the burden of proving authentication on the provider. What the regulations do not settle is the scope of a delegation exercised…
In short: agentic payments are the subject of HM Treasury’s Financial Services AI Adoption Plan and its Modernising Payment Services Regulation consultation, both published on 14 July 2026. Recommendation 10 proposes an agentic payments trust framework and a Know Your Agent standard. The consultation asks whether the PSRs 2017 need to change and closes on…
In short: Consumer Duty products and services monitoring asks a payment or e-money firm to show, not just assert, that its products give customers good outcomes. The FCA’s review of 10 July 2026 found firms that could describe their processes but could not demonstrate their interventions had worked. CP26/23 may make monitoring more explicitly proportionate…
In short: Finfluencer financial promotions are caught by the restriction in section 21 FSMA where they concern a controlled activity or a controlled investment, which covers consumer credit, qualifying cryptoassets and investments. The authorised firm behind the affiliate is responsible for the post, because section 21(13) treats causing a communication to be made as communicating…
In short: The Mills Review, published by the FCA on 6 July 2026, finds that accountability in retail financial services does not shift as AI takes on more of the work. The Senior Managers Regime still applies, firms remain answerable for AI-driven outcomes, and the report sets out seven recommendations for the FCA Board to…
In short: APP fraud reimbursement, mandatory over Faster Payments since 7 October 2024, cut in-scope scam losses by around 21% (about £73m a year) in its first year, the Payment Systems Regulator’s independent evaluation by Frontier Economics found on 1 July 2026. Reimbursement of losses rose from 54% to 65%. A formal consultation follows in…
In short: product level arrangements are the rules, standards and processes through which specific payment products will run on the UK’s next-generation payments infrastructure. In its update of 2 July 2026, the Payments Vision Delivery Committee set out its expectation of a single, centrally run core infrastructure scheme settling in central bank money, with competition…
In short: OFSI sanctions enforcement now carries real cost for the banks and payment intermediaries that process a transaction, not just the customers that instruct it. Between 19 March and 26 May 2026, OFSI fined Apple Distribution International £390,000, Deutsche Bank AG London Branch £165,000 and Sabre Global Technologies £1,000,920.59 for Russia sanctions breaches, all…
In short: CMA steering conduct requirements, proposed on 30 June 2026, would stop Apple banning, and Google restricting, the way UK app developers point their own customers to cheaper off-platform payment. A separate call for evidence asks how third parties should reach the iPhone’s contactless chip. Both close in late July 2026. By Rob Bratby,…
In short: The open banking competition regime is changing basis. Open banking began as a CMA competition remedy under the Retail Banking Market Investigation Order 2017. The smart data statutory instrument under Part 1 of the Data (Use and Access) Act 2025 is expected in Q4 2026 and would move it onto an FCA-supervised statutory…