UK payments regulation, open banking, FCA, PSR, scheme governance
In short: FCA open banking regulation sits today across three separate sources of law: the Payment Services Regulations 2017, the CMA Retail Banking Market Investigation Order 2017, and Part 5 of the Financial Services (Banking Reform) Act 2013. The 21 April 2026 modernisation package proposes to give the FCA new statutory powers to regulate the…
In short: On 6 May 2026 the FCA opened a Competition Act 1998 investigation into Mastercard, Visa and PayPal. The FCA Competition Act investigation covers all three under Chapter I, and Mastercard and Visa under Chapter II for suspected abuse of dominance, over how Mastercard and Visa cards fund the PayPal digital wallet. The FCA…
In short: the draft EU merger guidelines payments reset gives heavier weight to scale and resilience, formalises ecosystem theories of harm, and introduces the Innovation Shield for start-up acquisitions. The European Commission opened the public consultation on 30 April 2026 and feedback closes on 26 June 2026. UK and EU now sit on broadly aligned…
In short: The APP fraud reimbursement review is now running, with findings due during 2026/27. Mandatory reimbursement under Specific Direction 20 returned £173 million to victims in its first year. The £85,000 cap, the 50/50 split between sending and receiving payment service providers, and the consumer-caution exception are all on the table for recalibration. By…
In short: The CCI product summary is the FCA’s new disclosure document for retail investment products, replacing the EU-derived Key Information Document. Under FCA PS25/20, firms can adopt it from 6 April 2026 and must use it from 8 June 2027. Whether to switch early is a Consumer Duty question, not a technical compliance one….
In short: The PSR annual plan 2026/27, published 29 April 2026, sets three priorities for what may be the regulator’s last full year as a standalone body: implementing card fee remedies, publishing the first-year evaluation of mandatory APP fraud reimbursement, and planning the consolidation of PSR functions into the Financial Conduct Authority. Commercial variable recurring…
After a year of testing frontier AI models and legal-specific platforms, the problem was not capability but structure. A law firm cannot be built around a model. It needs a method in which AI operates under controlled, auditable workflows, with the lawyer as the final gate.
Competition Appeal Tribunal [2026] CAT 11 Trial 2 pass-on findings and the Administrative Court ruling in [2026] EWHC 64 (Admin) on the Payment Systems Regulator’s power under section 54 FSBRA 2013 to cap cross-border interchange fees.
HMT’s 22 April 2026 response to the SM&CR reform consultation, with FCA PS26/6 and PRA PS12/26, sets a package aimed at a 50% compliance burden reduction. The scope question comes first: pure APIs and EMIs sit outside SM&CR because the regime attaches to FSMA Part 4A authorised persons. Only dual-regulated firms are in scope.
FCA targeted support went live on 6 April 2026. The FCA/ICO joint statement of 11 December 2025 requires firms to get UK GDPR, PECR and Article 22 compliance in place before they send a single communication.
The FCA opened consultation on CP26/13: Cryptoasset Perimeter Guidance on 15 April 2026 (closes 3 June 2026), completing the FCA side of the UK’s dual-track stablecoin regime. On the Bank of England side, the £20,000 retail cap, £10 million business cap and 60:40 backing split in the November 2025 proposals face sustained industry pushback.
HM Treasury’s 21 April 2026 package consolidates the PSR into the FCA and integrates payment services and e-money regulation with the FSMA 2000 framework.