Product level arrangements: where competition will sit in the UK’s future retail payments ecosystem
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 developing at product level. The companion RPIB consultation closes 11 September 2026.
Anyone building a payment proposition on the UK’s next-generation infrastructure now has a clearer map of where the commercial opportunity will sit. The four authorities behind the National Payments Vision expect the new core to run as a single regulated utility, with competition developing in the product layer above it. The Payments Vision Delivery Committee frames its update of 2 July 2026 as discussion material for the live design consultation, yet it is specific on the structure of the core, on settlement and on the regulation of the operator.
From the National Payments Vision to the RPIB consultation
HM Treasury published the National Payments Vision on 14 November 2024 and established the Payments Vision Delivery Committee (PVDC), which brings together HM Treasury, the Bank of England, the Financial Conduct Authority and the Payment Systems Regulator. The PVDC’s Strategy for Future Retail Payments Infrastructure, published on 7 November 2025, set five outcomes for the renewal of the infrastructure behind Faster Payments and Bacs: choice, interoperability between forms of digital money, protection from fraud and financial crime, fair and non-discriminatory access, and operational and financial resilience.
The Retail Payments Infrastructure Board (RPIB), chaired by the Bank of England, opened its consultation on the design of the future retail payments infrastructure on 25 June 2026. That consultation, which closes on 11 September 2026, covers only the core clearing and messaging layer; it is set out in detail in next-generation retail payments infrastructure: the account-to-account question. The PVDC’s roles and responsibilities update of 2 July 2026 addresses the ecosystem that will sit around that core. The PVDC is careful about the document’s status: the update “is not a statement of policy or regulatory guidance and does not prejudge future work”, and exists to inform responses to the RPIB consultation.
What the PVDC now expects for the core infrastructure
The update states three structural expectations. First, the core will operate as a shared utility “delivered by centralised operating model”: a single core infrastructure scheme, developed and maintained by a single operator. Second, final settlement between customers of different money issuers will be in central bank money at the Bank of England, the anchor the PVDC identifies for monetary and financial stability. Third, the UK authorities expect the operator to fall within the regulatory frameworks for systemically important payment systems and financial market infrastructure.
The core infrastructure scheme will carry the rules and standards on participation, access, common technical standards, settlement arrangements, resilience, risk management, conduct and governance, with membership conditional on meeting those standards. The operator will need governance arrangements that support independence, avoid conflicts of interest and promote outcomes in the interests of the ecosystem as a whole.
The regulatory mechanisms already exist. HM Treasury can recognise a payment system as systemically important under Part 5 of the Banking Act 2009, bringing it under Bank of England supervision, and can designate a system for economic regulation under Part 5 of the Financial Services (Banking Reform) Act 2013 (FSBRA 2013). The PSR, and in future the FCA, will continue to regulate the core infrastructure; the Financial Services and Markets Bill 2026 provides for the transfer of the PSR’s functions to the FCA.
Product level arrangements: the competitive layer
Product level arrangements are the rules, standards and operational processes that make a specific payment product work consistently across multiple payment service providers. They typically cover payment initiation, consumer protection, dispute resolution, liability frameworks, commercial models and the applicable regulatory requirements, and a product scheme could deliver them. The PVDC expects several arrangements to coexist, spanning familiar journeys such as batch payments and open-banking initiated instant payments as well as new ones, and it identifies this layer as the part of the ecosystem “where greater competition will emerge”.
Three points stand out. First, the provider field is open: a product level arrangement could sit within a payment system, be run by an interface body, a term from the Data (Use and Access) Act 2025 covering bodies that set standards enabling access to account data on a customer’s behalf, or come from the core infrastructure scheme operator itself. Second, the PVDC expects coordination where a journey needs national scale. For account-to-account payments at the point of sale, it lists consistent branding and user experience, universal or interoperable acceptance arrangements, potentially including a universal point-of-sale kernel or QR standards, and standards addressing fraud, money laundering, dispute resolution, resilience and good outcomes for customers with vulnerable characteristics. The building blocks for that journey are set out on our open banking and VRPs page. Third, the PVDC expressly contemplates the commercial model: an arrangement may generate revenue from its participants and use it to pay core infrastructure scheme fees, reinvest in the product, or distribute it in accordance with the arrangement’s commercial model.
Two omissions matter as much as the content. The update does not cover the regulation of product level arrangements, and it does not prescribe market structures, access models or commercial arrangements, all of which the PVDC reserves for further analysis and engagement.
| Feature | Core infrastructure scheme | Product level arrangements |
|---|---|---|
| Role | Shared clearing and messaging utility for the ecosystem, with possible utility services such as directories and alias services | Rules, standards and processes that make a specific payment product work across multiple payment service providers |
| Structure | Single scheme, single operator, centrally run | Multiple arrangements coexist; products enter, adapt and exit over time |
| Who provides | The core infrastructure scheme operator | Payment systems, interface bodies, other bodies, or the core operator itself |
| Regulation | Bank of England and PSR (FCA in future); systemic recognition or designation expected | Not covered by the update; existing regulatory requirements continue to apply |
| Revenue | Membership and participation fees; surplus reinvested in resilience and long-term investment | Participant revenue; may fund core access fees, product reinvestment or distribution under the commercial model |
| Consumer protection | Supports an appropriate minimum level across the board | May provide enhanced protection depending on the payment journey and its risk |
Implications for payment service providers, schemes and fintechs
The near-term legal questions arise in the product layer. For payment service providers, prospective scheme operators and fintechs, the questions the PVDC raises concern payment scheme rules, participation agreements, liability frameworks and commercial models rather than infrastructure design. The regulatory context for scheme participants is set out on our PSR and scheme governance page.
Three practical threads follow. The first is neutrality. The core operator “may also provide other services at different points throughout the ecosystem and could include product level arrangements for core payment journeys”. A body that operates the utility and competes in the layer above it will test the fair-access outcome the PVDC Strategy set, and participants in competing arrangements will look closely at the governance and conflict-of-interest safeguards the PVDC contemplates.
The second is cost. The core operator’s revenue would come from membership and participation fees, payable by product level arrangements as well as by direct participants, and the operator should use any surplus to support the core’s resilience, maintenance and long-term investment. The PVDC accepts that pricing “will require further assessment and development”, which places access economics within the scope of consultation responses.
The third is timing. The RPIB consultation closes on 11 September 2026 and the update exists to inform responses to it; the PVDC has also committed to continue engaging across the payments ecosystem on these issues. If you are weighing participation in a payment scheme, or building one, our payments product, safeguarding and scheme governance page sets out where the legal questions concentrate.
Assessment
The update is expressly not a statement of policy, but it is specific on centralised delivery of the core, on settlement in central bank money and on systemic regulation of the operator. The treatment of the product layer remains open. A utility operator that can also provide product level arrangements raises a vertical-integration question familiar from other regulated infrastructure; the PVDC contemplates governance and fair-access safeguards in response. The update assigns liability frameworks, dispute resolution and commercial models to the product layer, and identifies coordination on acceptance, standards and consumer protection as the conditions for a payment journey to achieve national scale. The PVDC has asked for views on the boundary between the core scheme and the product layer; responses to the RPIB consultation are due by 11 September 2026.
Frequently asked questions
What are product level arrangements?
Product level arrangements are the rules and standards for a specific payment product or payment journey, defining how that use case operates across multiple payment service providers. They typically cover payment initiation, consumer protection, dispute resolution, liability, merchant acceptance and fee structures, and they enable competition at the product layer of the future retail payments ecosystem.
Who will operate the UK’s future core payments infrastructure?
A single operator will develop and maintain a single core infrastructure scheme, delivered through a centralised operating model. The RPIB is designing the core, an industry-led Delivery Company will build it, and Pay.UK continues to operate the existing retail interbank systems in the meantime.
How will the core infrastructure be regulated?
The Bank of England and the PSR, with the FCA taking the PSR’s role in future, will continue to regulate the core infrastructure. The UK authorities expect the operator to fall within the regimes for systemically important payment systems, which may include recognition under the Banking Act 2009 or designation under FSBRA 2013.
When does the RPIB consultation close?
The RPIB consultation on the design of the future retail payments infrastructure closes on 11 September 2026. The PVDC published its roles and responsibilities update on 2 July 2026 to inform responses, and it covers the ecosystem questions that sit alongside the core design.
