International developments remain highly relevant to UK payments firms operating through overseas subsidiaries, serving international customers or relying on cross-border infrastructure. The most significant changes include the EU’s PSD3 and PSR package, MiCA, mandatory instant euro payments, the US federal stablecoin regime and longer-term plans for a digital euro. FATF’s updated payment transparency standard also points to future changes in cross-border payment data and AML requirements.
Developments covered
🟧 Important/ Developing
AMLA: The new EU Authority for Anti-Money Laundering and Countering the Financing of Terrorism
The EU's new AML/CFT authority is writing the detailed single rulebook that applies from July 2027, and from 2028 will directly supervise up to 40 high-risk cross-border financial groups.
AMLA is the EU's new AML/CFT agency. It forms part of the 2024 AML package with the AML Regulation (AMLR) and the Sixth AML Directive.
For payments firms, the impact comes in two stages:
- First, the AMLR applies from 10 July 2027. From that date a single directly applicable rulebook on CDD, beneficial ownership and reporting replaces national implementations of the Fourth AML Directive.
- Second, AMLA will select up to 40 financial institutions or groups operating in at least six Member States for direct supervision from 2028
UK groups are affected through their EU-authorised EMIs, PIs and CASPs. These are AMLR obliged entities, and some may be eligible for AMLA selection.
Key dates
- January–March 2027 (expected): National supervisors collect final data from entities eligible for direct supervision and submit it to AMLA
- July 2027: AMLA begins selecting up to 40 entities for direct supervision (expected)
- 10 July 2027: AMLR applies
- End-2027(expected): Final selection communicated
- 2028: AMLA assumes direct supervision of the selected entities (expected)
Legal issue/risk
- EU subsidiaries of UK groups must comply with the AMLR from 10 July 2027, with limited time to implement final level 2 measures
- If a group is selected, AMLA replaces the home supervisor for AML/CFT, including enforcement. Selection turns on risk data submitted through national supervisors, so poor-quality data risks an adverse classification
- UK groups will run two diverging AML rulebooks, the AMLR and the UK MLRs
Next steps
- Count the Member States each EU entity operates in, including through passporting, to assess eligibility for direct supervision. Confirm the Q1 2027 data collection timetable with your home supervisor
- Gap-analyse EU AML controls against the AMLR and AMLA's draft RTS and guidelines, and track the final versions
- Align EU and UK group-wide AML frameworks
🟧 Important, uncertain timing/impact
EU PSD3 & PSR: Proposed reforms to the EU payments framework
The EU is developing a digital euro, a proposed central bank digital currency that could be used for retail payments online and offline. Its introduction remains subject to EU legislation and a decision by the European Central Bank.
Following political agreement, the package will significantly reform the EU payments framework. The PSR will introduce directly applicable rules on conduct, transparency, fraud liability and open banking, while PSD3 will cover authorisation and supervision, integrating electronic money institutions into the payment institution regime. Key reforms include mandatory payee name/IBAN verification, changes to APP fraud liability, enhanced Strong Customer Authentication (SCA) requirements and more prescriptive open banking standards.
Key dates
- 2026: Final texts expected in the Official Journal
- +18 months: PSR applies; PSD3 transposition deadline
- +24 months: Payee name/IBAN verification and fraud liability rules apply
- +24 months (extendable to 30): Reauthorisation window for existing PIs and EMIs
Legal issue/risk
The reforms will introduce a more harmonised EU regime, reducing national discretion and creating new compliance obligations for firms operating across Member States. Changes to fraud liability, payee verification and EMI reauthorisation are likely to have the greatest operational impact.
Next steps
- Assess the impact of PSD3 and the PSR on existing PSD2 compliance programmes, particularly fraud controls, SCA and open banking.
- Begin planning for payee name/IBAN verification capabilities and any required systems changes.
- Existing EMIs should prepare for reauthorisation under the new framework and monitor the final legislation.
🟧 Important/ Developing
Markets in Crypto-Assets Regulation (MiCA): Commission review
The Commission is reviewing whether MiCA remains fit for purpose now that the CASP transitional period has ended.
MiCA, the EU's market rules for cryptoassets, has applied in full since 30 December 2024. The transitional period for existing CASPs ended on 1 July 2026, or earlier where Member States opted for shorter periods, so crypto-asset services in the EU now require MiCA authorisation. In May 2026 the Commission launched public and targeted consultations on whether the framework remains fit for purpose. They covered:
- the boundary between MiCA cryptoassets and MiFID financial instruments
- stablecoin rules and the lack of an equivalence route for third-country issuers
- CASP requirements
- activities MiCA does not yet cover, including DeFi, staking, lending and tokenised deposits
Responses feed the Commission's report under Articles 140 and 142, due by 30 June 2027, which may be accompanied by a legislative proposal. Separately, the Commission's December 2025 MISP proposals would transfer CASP supervision to ESMA, and negotiations currently point towards covering significant CASPs only. For UK payments firms, the review matters for groups with EU crypto or e-money token activity. It also matters for how far the EU and UK regimes diverge ahead of UK go-live on 25 October 2027.
Key dates
- 30 December 2024: MiCA fully applies
- 1 July 2026: Grandfathering period ends; CASP authorisation required
- 30 June 2027: Commission report on MiCA's application, with a legislative proposal where appropriate (confirmed statutory deadline)
- TBC: Agreement on MISP, including ESMA direct supervision of CASPs (expected; in negotiation)
Legal issue/risk
- Firms providing crypto-asset services in the EU must confirm whether they require MiCA authorisation and whether any applicable national transitional arrangements remain available. Operating without the necessary authorisation creates enforcement and market-access risks.
- The review could reopen scope, stablecoin requirements and third-country treatment. Current compliance builds for CASPs and token issuers may need revisiting after June 2027
- If MISP is adopted, significant CASPs would move to ESMA supervision, which would change supervisory relationships and reporting lines
Next steps
- Track the Article 140 report and any accompanying proposal, and engage through trade bodies as the proposal develops
- Monitor MISP negotiations, particularly how "significant" CASPs are defined for ESMA supervision
- Map MiCA obligations against the UK regime (PS26/9 to PS26/13) for dual-jurisdiction groups, prioritising stablecoin issuance and disclosure
🟧 Important, uncertain timing/impact
The GENIUS Act and implementing rules
US regulators are consulting on the rules that will govern who can issue, offer and sell payment stablecoins in the US, including issuers based abroad.
The GENIUS Act is the first US federal framework for payment stablecoins. Only permitted payment stablecoin issuers (PPSIs) may issue in the US. Stablecoins must be backed one-to-one by a closed list of reserve assets, be redeemable at par and be supported by regular reserve disclosures, and issuers may not pay holders interest or yield. A foreign issuer can access the US market only if Treasury determines its home regime is comparable to the US framework and the issuer registers with the OCC.
Implementing rules are now arriving. The Treasury Department's August 2026 proposal defines when a stablecoin is issued, offered or sold in the US. It applies extraterritorially and gives offshore issuers a reasonable-belief route out of the issuance prohibition. The Federal Reserve's September 2026 proposal sets reserve, capital, risk-management and custody rules for the issuers it supervises, plus an anti-tying rule for all PPSIs. OCC, FDIC and NCUA proposals have also been published, but none has been finalised.
For UK firms the relevance is US distribution. That covers UK stablecoin issuers, cryptoasset platforms with US customers, and payments firms integrating US-issued stablecoins. Read alongside the PS26/10 and BoE systemic stablecoin entries.
Key dates
- 19 October 2026: Treasury consultation on issuance, offer and sale closes
- November 2026 (expected): OCC final rule targeted
- 30 November 2026: Federal Reserve consultation closes
- 18 January 2027: Act takes effect
- Up to 12 months from 18 January 2027: Regulators may waive requirements for issuers with applications pending at the effective date (provisional; discretionary)
- 18 July 2028: Digital asset service providers barred from offering or selling to US persons payment stablecoins not issued by a PPSI or a qualifying foreign issuer
- TBC: Treasury process for foreign-regime comparability determinations (not yet proposed)
Legal issue/risk
- Issuing a payment stablecoin in the US other than as a PPSI or qualifying foreign issuer is unlawful. Knowing participation carries criminal penalties. Treasury's proposal would treat white-label branding partners, market makers and platforms that list a stablecoin at issuance as potential participants
Next steps
- Review the US Treasury’s consultation proposals and monitor the resulting implementing rules, particularly their implications for overseas stablecoin issuers and distributors.
- Bank-affiliated issuers and firms with views on anti-tying or yield should consider responding to the Fed proposal by 30 November 2026.
🟧 Important, uncertain timing/impact
EU Instant Payments Regulation (SEPA Instant)
The EU Instant Payments Regulation introduces phased requirements for in-scope payment service providers offering euro credit transfers to support instant payments, generally within 10 seconds and available around the clock.
The Regulation is designed to make instant euro payments the default across SEPA by requiring PSPs that offer standard euro credit transfers to also provide instant payments at no higher cost. It also introduces mandatory Verification of Payee and simplified sanctions screening to improve fraud prevention while maintaining fast payment processing. Implementation is phased across Euro and non-Euro Member States.
Key dates
- 9 January 2027: Non-euro area PSPs must receive instant payments; charge parity applies
- 9 April 2027: Euro area payment and e-money institutions must send and receive instant payments
- 9 July 2027: Non-euro area PSPs must send instant payments; Verification of Payee applies
Legal issue/risk
The Regulation introduces new operational and compliance obligations around instant payments, Verification of Payee and sanctions screening. Firms operating across the UK and EU should also consider interoperability and compliance across different payments frameworks.
Next steps
- Upgrade payment infrastructure to support SEPA instant payments and charge parity.
- Implement Verification of Payee and updated sanctions screening processes.
- Review fraud controls and operational readiness for the phased implementation dates.
- UK firms with EU operations should plan for the staggered implementation timetable.
🟩 Long-term/indicative
The G20/ FSB Cross-Border Payment Targets - new goals expected in 2027
The FSB's cross-border payment targets, set in 2021, expire at the end of 2027 and the organisation is beginning to look at the next steps for cross-border payments
The FSB will likely announce new cross-border payment targets before the current ones expire at the end of 2027.
In 2021, the FSB, on direction from the G20, set targets for making cross-border payments faster, cheaper, more accessible, and more transparent. Though there has been some progress, it is unlikely any of the goals will be achieved by the end-2027 deadline. In March 2026, the FSB launched a new implementation phase focused on jurisdictional and regional action plans and closer public-private collaboration.
No successor targets have been announced. In July 2026 the FSB Deputy Secretary General, speaking in a personal capacity, called for a debate on the next steps for cross-border payments beyond 2027.
Key dates
- October 2026 (expected): FSB cross-border payments annual progress report, including KPI results
- 2026 (expected): Institute of International Finance report with its assessment and industry recommendations for a path forward for the G20 agenda
- Early 2027 (expected): FSB review of implementation of its policy recommendations on data frameworks and on bank and non-bank supervision and regulation
- End-2027 (confirmed): Deadline for the speed, access, transparency and retail cost targets
- 2030 (confirmed): Remittance cost target (global average ≤3% on a $200 remittance; no corridor above 5%)
- Undated: Any decision on post-2027 targets or a successor roadmap
Why it matters
- There are no direct obligations. FSB activities and decisions are not binding and do not create legal rights or obligations. Exposure arises only through UK (BoE, FCA/PSR, HMT) or EU implementation
- The transparency target is the most firm-facing element. It overlaps with existing UK disclosure duties under the PSRs 2017 and Consumer Duty. Supervisors and competitors may use it as a benchmark for good practice
Next steps
- Benchmark cross-border products against the speed, cost and transparency targets, especially last-mile crediting and upfront FX and fee disclosure
- Review the October 2026 progress report and KPI data for corridors relevant to your business
🟩 Long-term/indicative
Digital Euro
PSD3 and the Payment Services Regulation (PSR) will replace the current EU payments framework, introducing a more harmonised regime for payment service providers across the EU.
The proposed framework would introduce a retail central bank digital currency (CBDC) that can be used online and offline alongside existing payment methods. The legislation includes provisions on privacy, holding limits and legal tender status, while also setting the framework for consumer pricing and merchant access. Final implementation remains subject to legislative approval and an ECB decision to issue the digital euro.
Key dates
- 2026 (indicative): EU legislative negotiations on the proposed digital euro framework.
- 2029: Earliest potential issuance, subject to ECB decision
Why it matters
No immediate obligations arise, but firms operating in Europe should monitor the development of the digital euro, particularly its potential impact on payment models, interoperability and future compliance requirements. Differences between the EU digital euro and UK digital currency initiatives may also affect cross-border payment services.
Next steps
- Monitor legislative progress and ECB decisions on the digital euro.
- Assess the potential impact on payment products, customer demand and operating models.
- Participate in industry engagement where relevant and consider future interoperability requirements.
🟩 Long-term/indicative
FATF updates Recommendation 16 (Payment Transparency)
The Financial Action Task Force (FATF) has updated Recommendation 16 to strengthen transparency requirements for cross-border payments and improve the traceability of payment information.
The revised Recommendation, renamed Payment Transparency, extends the Travel Rule beyond traditional wire transfers to cover cross-border payments and value transfers more broadly. It clarifies responsibilities across the payment chain, introduces more consistent originator and beneficiary information requirements for higher-value payments, encourages the use of payee verification and other anti-fraud tools, and clarifies the treatment of card payments. While the changes are not directly binding, they are expected to be reflected over time in national AML regimes, including the UK’s Money Laundering Regulations.
Key dates
- End of 2030: FATF implementation deadline for member jurisdictions
Why it matters
The changes do not create immediate obligations, but future UK implementation is likely to strengthen requirements around payment transparency, data quality and cross-border payment messaging. Firms should also monitor developments relating to payee verification and AML controls.
Next steps
- Monitor UK implementation through HM Treasury, the FCA and Money Laundering Regulation reforms.
- Assess the quality of cross-border payment data and alignment with structured messaging standards such as ISO 20022.
- Review plans for payee verification and other fraud prevention capabilities.
- Engage with industry initiatives as implementation guidance develops.