On 7 November 2025, HM Treasury published the Payments Vision Delivery Committee's (PVDC) strategy setting out long-term goals for the UK’s retail payments infrastructure. The strategy is informed by, and builds on, the three pillars of the National Payments Vision: innovation, competition and security. In order to future-proof the strategy, it is anchored around five high-level strategic outcomes:

1. Consumers and businesses have a greater choice of innovative and cost-effective payment options that meet their needs. The new infrastructure will need to: support delivery of account-to-account payments, including by supporting Open Banking; improve existing payment use cases/facilitate new payment use cases (eg via programmable functionalities and tokenisation); explore use of alias-based payments, consistent with Outcome 3; reduce barriers to making cross-border payments eg through improved international interoperability via standardised messaging formats, and supporting stablecoin payments; be ‘inclusive by design’; enable modular development and seamless integration of value-adding overlay services.
2. Payments operate seamlessly as part of a diverse multi-money ecosystem, with interoperability between new and existing forms of digital money. The new infrastructure will need to: support innovation in new forms of digital money and payments; facilitate interoperability across different types of digital money.
3. Consumers and businesses can trust that their payments are protected from fraud and wider financial crime. Among other things, the new infrastructure will need to: support the fight against financial crime by enabling advanced capabilities in prevention, detection and resolution (eg via use of high-quality data and AI-driven analytics). Financial crime should be ‘designed-out’ as far as possible, eg via programmable payments to enable conditional settlement, dynamic transaction limits and payments to pre-approved recipients.
4. Participant firms have fair, transparent and non-discriminatory access to the infrastructure – maximising competition and scope for innovation across the payments ecosystem (in support of Outcome 1). The new infrastructure will need to: support a range of commercially viable business models; provide easier access to payment services providers and relevant other types of service provider that meet the necessary requirements, including compliance with regulation; have a transparent, fair and predictable pricing methodology and governance framework.
5. The payments ecosystem is operationally and financially resilient. Among other things, the new infrastructure will need to: include the highest levels of protection from cyber and wider threats; employ a funding model that enables ongoing investment; to ensure monetary and financial stability, continue as with current practice for systemic retail payment systems to facilitate final settlement in central bank money for payments between customers of different money issuers.

The PVDC will continue to coordinate closely to achieve the above outcomes, including monitoring developments and innovation in payment systems, including in other jurisdictions.

To achieve world-leading payments, the PVDC's priority areas are for the next generation infrastructure to:

• deliver ‘account-to-account’ functionality at point of sale, to enable greater choice of payment methods; and
• support innovation – including programmable payments, tokenised deposits, and stablecoins.

The strategy paper refers to the fact that Pay.UK is already undertaking important work on short-term enhancements to the current Faster Payment System and the Bacs Payment System, with a view to improving resilience and better supporting innovation.

In line with the new governance model announced in July 2025, the Bank of England has convened (and will chair) the Retail Payments Infrastructure Board (RPIB) to lead the design (and delivery oversight) of the renewed retail payments infrastructure in accordance with the strategy. The RPIB will develop a workplan that delivers on the strategy and also takes account of changes across the wider ecosystem and relevant regulatory initiatives.

Payments ecosystem participants are also setting up an industry-owned Delivery Company, responsible for implementing the design – procuring and funding the next-generation infrastructure.

Given the timescales involved in the design and delivery of the new retail payments infrastructure, the PVDC welcomes potential wider private sector innovations in the interim that support the strategy's outcomes.

On 18 November 2025, the PRA published a policy statement (PS24/25) on increases to the deposit protection limits under the Financial Services Compensation Scheme (FSCS). Some key points from the policy statement are:

• The deposit protection limit is being increased from £85,000 to £120,000 and the temporary high balance limit from £1 million to £1.4 million, both taking effect from 1 December 2025. The updated versions of Supervisory Statement SS18/15 and Statement of Policy SoP1/15 will also apply from that date. The PRA proposed increasing the deposit protection limit to £110,000 in its March 2025 consultation (CP4/25), but has settled on a new total of £120,000 due to respondents’ feedback and the latest inflation data.
• Deposit taking firms are also required to update their single customer view (SCV) systems to reflect the new limits from 1 December 2025.
• There is a transitional period to 31 May 2026 for consequent changes to the information firms are required to disclose to depositors and other consumers to reflect the updated protection limits as well as ensuring information on the FSCS more generally remains clear and easy to understand.
• There are some further (mainly clarificatory/confirmatory) amendments to the previously proposed changes to the Depositor Protection Part (DPP) of the PRA Rulebook and related Supervisory Statement (SS18/15).

The FSCS has made information available on its website to assist firms in relation to the new limits and information requirements.

Take a look at this Our Thinking article for more on this development.

On 23 October 2025, the Bank of England (BoE) published a progress update on its ongoing work to explore the case for a digital pound.

The update confirms that no decision has yet been made on whether to introduce a digital pound, but outlines the BoE's priorities for 2026, including finalising a detailed blueprint and continuing stakeholder engagement. The BoE's work to date has focused on three key areas: technical experimentation through the Digital Pound Lab, interoperability with existing and emerging forms of money, and gathering stakeholder input to inform design choices.

The BoE has also published new design notes on topics such as interoperability models, product strategy, offline payments, and alias services. These notes reflect the BoE's emerging thinking on how a digital pound could support innovation, financial inclusion, and the UK's broader National Payments Vision.

The blueprint and accompanying assessment are expected to be published in 2026 and will inform a joint decision by the BoE and HM Treasury on whether to proceed with further development of a digital pound.

On 30 October 2025, the European Central Bank (ECB) announced it is transitioning the digital euro project from its preparation phase into its next stage, following successful groundwork laid between November 2023 and October 2025. The ECB Governing Council has confirmed that – assuming the EU co-legislators adopt the required Regulation during 2026 – a pilot phase could begin in mid 2027, with readiness for a possible first issuance by 2029.

The preparation phase included establishing foundational elements such as rulebooks, technical infrastructure, privacy design and stakeholder engagement. The decision aligns with political encouragement from European leaders at the October 2025 Euro Summit.

Key priorities for this next phase include:

• Building technical readiness for issuance;
• Launching pilot systems for user testing; and
• Supporting the EU’s legislative process.

ECB President Christine Lagarde emphasised that a digital euro would enhance payment innovation, resilience, privacy and European monetary sovereignty, while complementing but not replacing cash. The final decision to issue will only follow the adoption of the digital euro Regulation by the EU legislatures.

On 23 October 2025, the PSR and FCA jointly responded to HM Treasury's (HMT) consultation on consolidating the PSR's functions into the FCA, welcoming the proposal as it preserves the PSR's core duties – competition, innovation and consumer protection – while enabling a more cohesive regulatory approach. They noted that joint initiatives – such as shared project teams, an updated Memorandum of Understanding with the Bank of England and the PRA, and cooperation on issues like digital wallets and fraud – already illustrate the benefits of a streamlined structure. The regulators confirmed continued collaboration with HMT to ensure smooth legislative integration.

For further background on HMT's consultation, see this previous Our Thinking article.

On 30 October 2025, the Bank of Ghana (BoG) launched its National Payment Systems Strategy 2025–2029 to accelerate open banking adoption and integrate a national digital ID framework to enhance interoperability and security across payment systems. Speaking at the National Payment Systems Workshop, the BoG’s First Deputy Governor highlighted key initiatives to strengthen the country’s payment ecosystem, including:

• The rollout of open banking and data-sharing frameworks to support interoperability and innovation;
• The implementation of electronic Know Your Customer systems for streamlined onboarding; and
• Deployment of trusted digital identity solutions to lower barriers for banks and non-bank entities.

The First Deputy Governor highlighted these initiatives as critical to driving financial inclusion and supporting innovation in Ghana’s fast-growing digital economy. He also cautioned against growing cybersecurity and fraud risks, urging continued collaboration across regulators, fintechs, banks, and mobile money operators. The BoG also signalled upcoming regulatory guidelines to govern API standards and data-sharing protocols for banks and fintechs.

Stakeholders – including banks, fintechs, and development partners – were invited to contribute to the draft strategy, which will guide Ghana’s payment systems policy and investment landscape through to 2029.

On 4 November 2025, the government laid the Financial Services and Markets Act 2000 (Regulated Activities etc.) (Amendment) (No. 2) Order 2025 (the Amendment Order), exempting domestic premises suppliers from requiring credit broking permissions when offering buy now, pay later (BNPL) products.

The Amendment Order follows a June 2025 HM Treasury policy paper and feedback from stakeholders and the FCA (see more in the July 2025 edition of the Newsletter), which emphasised that licensing requirements for in‑home sellers could overburden small businesses and restrict consumer access to interest‑free credit for low‑value purchases.

The new BNPL regime introduced by the Financial Services and Markets Act 2000 (Regulated Activities etc) (Amendment) Order 2025 (as amended by the Amendment Order) will come into effect on 15 July 2026. It will include a Temporary Permissions Regime for firms that do not currently hold required authorisations. The FCA's consultation on detailed rules for regulated BNPL firms closed on 26 September 2025, with a policy statement and final rules expected in early 2026.

See this Our Thinking article for links to further related publications on the new BNPL regime.

On 20 October 2025, the Bangko Sentral ng Pilipinas (BSP) released a draft circular proposing tougher penalties for operators that submit inaccurate or late payment data reports. Key details include:

• Monetary fines: up to PHP 3,000/day for large banks; PHP 2,000 for digital banks; PHP 1,500 for thrift banks; PHP 450 for rural banks; PHP 1,000 for non bank providers;
• One-off resubmission window to correct non-compliant reports before penalties apply; and
• Non-monetary sanctions may include suspension or disqualification of directors or officers.

The move supports the BSP’s broader strategy to boost governance, accountability, and real-time monitoring in the rapidly growing digital payments ecosystem, where digital transactions comprised 57.4% of retail volumes in 2024.

The stakeholder comment period for the draft circular closed on 21 November 2025.

On 28 October 2025, the Australian Treasury released the draft Payment Systems Legislation Amendment (2025 Measures No. 1) Regulations 2025 and a related draft explanatory statement for consultation.

The purpose of the draft Regulations is to support the amendments in Schedule 1 to the Treasury Laws Amendment (Payments System Modernisation) Bill 2025. Schedule 1 amends the Payment Systems (Regulation) Act 1998 (PSRA) to modernise the payments regulatory framework, ensuring it is fit-for-purpose and can address emerging risks related to payments. The Bill was passed by both Houses of Parliament on 4 September 2025.

The consultation closed on 11 November 2025.

On 5 November 2025, HM Treasury (HMT) published a national Financial Inclusion Strategy, and on 4 November Nikhil Rathi, FCA Chief Executive, delivered a related speech at the Fair4All Finance Delivering Financial Inclusion Together Conference.

The Strategy aims to address specific challenges from its three cross-cutting themes of mental health, accessibility and economic abuse as well as looking to embed a more inclusive approach across financial services more generally.

Among other things, the Strategy highlights the further opportunities that the National Payments Vision presents to embed and support financial inclusion, eg in the design of the new retail payments infrastructure, the work of HMT, the FCA and the Payment Systems Regulator on progressing the development of Open Banking-enabled variable recurring payments, and the importance of financial inclusion to the development of the forthcoming Payments Forward Plan which will contain a sequenced plan for future payments initiatives.

This Our Thinking article highlights some further key takeaways for financial services firms.

On 24 October 2025, HM Treasury announced the launch of a new Scale-up Unit jointly led by the FCA and the PRA. Initially focused on dual regulated firms (banks/building societies and insurers), plans to expand the Unit's scope to solo regulated firms will be announced in Spring 2026. Part of the government's pro-growth agenda, the new Unit is designed to "supercharge" the growth of innovative financial services firms. New webpages on the Unit have also been published by the FCA and the PRA. Take a look at this Our Thinking article for more details.

As part of its wider financial crime supervisory work in support of its 2025–30 strategy, on 11 November 2025 the FCA published the findings from its multi-firm review of firms' business-wide risk assessment (BWRA) and customer risk assessment (CRA) processes.

Firms involved in the review included building societies, platforms, custody and fund services, payments (e-money) and wealth management firms. The FCA focused on how firms:

• Identify, understand and assess risk: Key challenges include tailored risk assessments, quantitative analysis, the need for BWRA and CRA processes to work in harmony, and good governance.
• Appropriately mitigate risk: Key points include the capacity of compliance and financial crime functions to support firms’ current and future growth strategy, the need for risk assessments, decision-making and monitoring activities to be joined up, the need for financial crime risk to be at the heart of business decisions and strategy, and good governance.
• Effectively manage risk: Key points include that CRA is an essential part of conducting business, senior management’s understanding of financial crime risk should include the full range of relevant risks (not just those targeted at the firm such as fraud risk), and good governance.

While the FCA expects firms to already be complying with existing requirements in terms of understanding relevant risks and having robust financial crime systems and controls in place, it is encouraging firms to use its findings to review their current approach. It will continue to monitor firms through its supervisory work to make sure they are considering the points raised in the review with a view to making any necessary improvements.

See this Our Thinking article for more on the FCA's findings.

On 18 November 2025, the Payment Systems Regulator (PSR) published a compliance report on Specific Direction 17 (SD17), which required "Group 1" payment system providers (PSPs) to use a confirmation of payee (CoP) system by October 2023 and "Group 2" PSPs by October 2024. The PSR has been monitoring firms' compliance with SD17 since October 2024. Key points from the compliance report include:

• Over 320 organisations offer CoP checks in the UK, with CoP covering around 99% of the payments market by October 2024.
• The PSR is continuing to monitor a small group of firms that still do not have a CoP system. It has opened three enforcement investigations into Group 2 firms who did not meet the deadline. If, following an investigation, the PSR's Enforcement team find that there has been a compliance failure, it may decide to refer the case to the Enforcement Decisions Committee.
• Firms who may not previously have conducted relevant business, but begin to do so, are required to implement a CoP system. The PSR will continue to monitor market data to identify PSPs who may meet the definition.

On 28 October 2025, the PRA published a policy statement (PS20/25) on near-final rules for the simplified capital regime for small domestic deposit takers (SDDTs) under the strong and simple framework. The policy statement represents the second and final phase of the PRA's strong and simple initiative.

The PRA has not published its final rules for the SDDT capital regime as the Pillar 1 requirements for SDDTs will be based on the final rules for the implementation of Basel 3.1, which have not yet been published.

The PRA intends to publish a policy statement in Q1 2026 setting out its final policy and rule instruments relating to the simplified capital regime for SDDTs. This policy statement will be published alongside, or shortly after, its policy statement on its final rules on the implementation of Basel 3.1.

Broadly, the final rules for the SDDT capital regime, and related changes to supervisory materials, are intended to come into force on 1 January 2027.