Several strands of payments policy that developed separately are now converging. Cryptoassets are moving into a dedicated regulatory perimeter, while the wider payment services framework is being recast around a more flexible FCA rules-based model. Stablecoin payments are being brought within that framework, competition authorities are intervening in card fees and mobile platforms, and commercial account-to-account payments are developing their own rules and economics. At the same time, existing consumer law is being applied to new forms of AI-enabled commerce. These are separate workstreams, but together they are changing how payments are regulated and where costs, risks and responsibilities sit across the value chain.
Much remains open to influence. HM Treasury’s payment services consultation closes on 6 October and covers strong customer authentication, stablecoin payments, open banking and agentic payments. The PSR is developing the methodology for a potential longer-term cross-border interchange cap and pursuing greater transparency around scheme and processing fees. The CMA is considering steering requirements for Apple and Google and expects to consult in the autumn on potential measures for NFC access on iOS. Meanwhile, the commercial model for the next phase of commercial VRP, including fees, purchase protection and liability, continues to develop.
Behind these immediate issues sit longer-term reforms: the FCA’s open finance roadmap, the future regulatory framework for open banking and wider work on Consumer Duty. International developments matter too, with MiCA now fully applicable in the EU, the digital euro progressing through its development and legislative process, and the US implementing a federal framework for payment stablecoins. For firms operating across markets, the extent to which these regimes align will influence the cost and complexity of developing cross-border products and services.
“Much of payments regulation applies directly to providers, but its effects reach merchants through cost, contracts and the customer experience. Merchant voices need to be part of the regulatory conversation.”
Renuka Rawlins, Director of Policy and Government Relations, The Payments Association
Across much of this agenda, members share an interest in proportionate rules, regulatory certainty, and effective competition. But interests are not identical. The allocation of APP fraud costs, the commercial impact of greater fee transparency, and the design of the next phase of commercial VRP can affect different participants in different ways. The Payments Association’s role is to represent those perspectives rather than assume a single industry position.
For merchants, an important distinction runs throughout this roadmap. A relatively small number of developments create direct compliance obligations, including pricing and reviews, the use of AI in customer interactions, and, from spring 2027, the subscription contract regime. Many others affect merchants indirectly through payment costs, provider requirements, customer journeys, or contractual terms.
That makes commercial engagement as important as regulatory monitoring. Merchants should understand what sits behind their acquiring costs, ask providers how regulatory changes will affect their services, and contribute evidence while policy remains open to influence. HM Treasury’s consultation, which closes on 6 October, is one immediate opportunity for members to shape reforms with potentially significant consequences for merchant payments.