UK payments regulation, open banking, FCA, PSR, scheme governance
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…
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: The FCA opened a Competition Act 1998 investigation into Mastercard, Visa and PayPal in March 2026; the FCA publicly confirmed the investigation on 6 May 2026. 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…
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 consulted on the draft from 30 April to 26 June 2026; adoption is expected in the fourth quarter of 2026 or early 2027,…
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 26 March 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.