PSR annual plan 2026/27: card fees, APP fraud and the road into the FCA
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 payments sit alongside as a separate Open Banking workstream.
The PSR annual plan 2026/27, published by the Payment Systems Regulator on 29 April 2026, sets a delivery agenda for what may be the regulator’s last full year as a standalone body before consolidation into the FCA. The plan confirms three priorities for the year: implementing card fee remedies, including the cross-border interchange cap upheld by the Administrative Court on 15 January 2026; publishing and responding to the first-year evaluation of mandatory authorised push payment fraud reimbursement; and planning the orderly transfer of PSR functions to the FCA. Commercial variable recurring payments sit alongside those three as a separate Open Banking workstream.
Key findings (PSR annual plan 2026/27)
- The PSR will continue to enforce the UK-EEA cross-border interchange fee cap and develop domestic scheme and processing fee remedies. Source: PSR press release, 29 April 2026.
- The PSR will publish the first independent evaluation of the mandatory APP fraud reimbursement regime that took effect on 7 October 2024 and respond to its findings during 2026/27. Source: PSR annual plan 2026/27, p.3.
- The PSR is preparing for consolidation into the FCA, with the document framed around continuity, clarity and certainty for regulated firms.
- Commercial variable recurring payments work continues under the Joint Regulatory Oversight Committee framework, building on the PSR’s December 2025 cVRP policy statement.
- The plan operates against the backdrop of the National Payments Vision published by HM Treasury in November 2024.
| Priority | Workstream | Statutory base |
|---|---|---|
| Card fees | Cross-border interchange caps; domestic scheme and processing fee remedies | FSBRA 2013 s.54 (general directions); s.55 (system rules) |
| APP fraud | Independent evaluation of year one; receiving-PSP standards | FSBRA 2013 s.103A; PSR Policy Statement PS24/1 |
| Consolidation | Transfer of PSR functions to the FCA | HM Treasury Regulatory Action Plan, March 2025 |
| Open Banking | Commercial variable recurring payments expansion | JROC framework; PSR cVRP policy statement, December 2025 |
The 2026/27 plan in context
The PSR annual plan 2026/27 is the first work programme the regulator has published since the government confirmed in March 2025 that PSR functions will consolidate into the FCA. The plan operates within the regulator’s three statutory objectives in sections 50 to 52 of the Financial Services (Banking Reform) Act 2013: competition, innovation and the interests of service-users. The regulatory principles in section 53, including proportionality and the desirability of sustainable growth, frame the way the regulator pursues those objectives. The general direction power in section 54 and the system-rules power in section 55 are the tools the plan uses. Eight payment systems sit within the regulator’s remit, including Bacs, CHAPS, Faster Payments, LINK, Mastercard and Visa.
Card fees: cross-border interchange and domestic scheme remedies
Card fees are the largest workstream in the plan. The PSR will continue to enforce the UK-EEA cross-border interchange fee cap, which survived judicial review in Mastercard v PSR [2026] EWHC 64 (Admin). Cavanagh J held that section 54 is broad enough to support price regulation of fees within payment systems, that commercial impact on scheme operators is not a ground to invalidate a direction, and that the regulator does not need to demonstrate actual harm before acting preventively. The judgment is the settled legal foundation for the cap. The Competition Appeal Tribunal’s pass-on findings in [2026] CAT 11 are a separate matter, settling the pass-on methodology in the merchant interchange litigation against the schemes (with quantum to be addressed at Trial 3). Domestic scheme and processing fee remedies are the other half of the card fees workstream. The plan signals that draft directions and rule-changes are expected during 2026/27 to address the competition concerns the PSR identified in its review of those markets. We covered the litigation outcomes in our earlier analysis of CAT Trial 2 and the PSR cap judicial reviews.
APP fraud: year-one evaluation and the second year of mandatory reimbursement
Mandatory authorised push payment fraud reimbursement, which took effect on 7 October 2024 under PSR Policy Statement PS24/1 and section 103A of FSBRA 2013, is now in its second year. The plan commits the regulator to publishing the first independent evaluation of the regime and responding to its findings during 2026/27. The PSR is also expected to consult on receiving-PSP standards in light of the year-one data. We set out the regime structure and the open compliance questions in our analysis of cross-sector APP fraud reimbursement liability.
Commercial variable recurring payments and the Open Banking workstream
Commercial variable recurring payments sit outside the three priority workstreams but remain a live agenda item. The PSR’s December 2025 cVRP update on delivery, issued jointly with the FCA, set the framework for cVRP rollout under the Joint Regulatory Oversight Committee. The plan signals that participation rule-development continues during 2026/27, and that the smart data provisions in Part 1 of the Data (Use and Access) Act 2025 will sit alongside the PSR’s framework as the wider statutory basis for Open Banking-adjacent data sharing. cVRPs touch on AI-mediated payment consent, which we explored in our piece on agentic AI payment consent.
Consolidation: from PSR to FCA single rulebook
The third priority is the PSR’s preparation for transfer of its functions into the FCA, following the HM Treasury Regulatory Action Plan published in March 2025. The plan describes the consolidation work in operational terms: continuity of supervision, clarity for regulated firms, and certainty about which rules continue to apply during the transition. The legislative timing is not in the regulator’s hands. The transfer requires primary legislation that has not yet been introduced. Until that legislation passes, the PSR remains a separate statutory body with the FSBRA 2013 toolkit unchanged. We tracked the consolidation announcement and the streamlined approach consultation in our earlier piece on PSR/FCA consolidation and in our analysis of the streamlined payment systems consultation.
Implications for payment firms
For card schemes and acquirers, the plan signals that the legal arguments on cross-border interchange are over and the regulator’s attention turns to compliance with the cap and to the next round of domestic fee remedies. The next remedies may travel by either route in the FSBRA 2013 toolkit: a section 54 direction on participants, or a section 55 system-rules requirement on the scheme operator. The route the PSR picks will determine where the compliance burden lands. For PSPs in the Faster Payments and CHAPS perimeter, the year ahead is about the second year of mandatory reimbursement: year-one operational data will inform the rule-changes the PSR consults on next, and the receiving-side compliance bar is likely to rise. For Open Banking participants and aspirant cVRP providers, the plan confirms that participation framework development is on a delivery track but does not commit to a sector-specific go-live date.
Frequently asked questions
When was the PSR annual plan 2026/27 published?
The PSR annual plan and budget 2026/27 was published by the Payment Systems Regulator on 29 April 2026. It is available on the PSR’s publications page. The press announcement was titled “PSR to press ahead on card fees, fraud and payments reform in 2026/27”.
What are the three priorities in the PSR annual plan 2026/27?
The plan sets three priorities: implementing card fee remedies (cross-border interchange caps and domestic scheme and processing fee remedies); publishing and responding to the independent first-year evaluation of mandatory APP fraud reimbursement; and planning the consolidation of PSR functions into the FCA. Commercial variable recurring payments and the wider Open Banking workstream sit alongside these three.
Will PSR powers transfer to the FCA?
Government policy is to consolidate PSR functions into the FCA, set out in HM Treasury’s Regulatory Action Plan in March 2025. The transfer requires primary legislation that has not yet been introduced. Until that legislation passes and commences, the PSR remains a separate statutory body and the FSBRA 2013 powers continue to be exercised by the PSR.
When will commercial variable recurring payments roll out?
The PSR’s December 2025 cVRP policy statement set the framework for rollout under the Joint Regulatory Oversight Committee. The annual plan 2026/27 commits the regulator to continued participation rule-development but does not announce a sector-specific go-live date. cVRP rollout will depend on Open Banking infrastructure readiness and on participant adoption.
Does the PSR annual plan 2026/27 cover APP fraud?
Yes. APP fraud is one of the three priorities. The PSR will publish the first independent evaluation of the mandatory reimbursement regime that took effect on 7 October 2024, and will respond to its findings during the year. Receiving-PSP standards are expected to be developed in light of the year-one data.
