Payments View

Current edition

September 2025

This edition includes updates on:

• A Phaedo for the Modern Age – PSR publishes annual report in the midst of getting axed
• HMT Consultation on Said Axing
• Contactless Limit Being Removed
• FCA Simplifying Supervisory Communications
• Mansion House Speech and Leeds Reform – ‘Unlocking Growth’ in Financial Services
• Deferred Payment Credit Regulation – FCA Consultation
• FCA’s Secondary Objective – Progress Update
• Concerns raised over Bank of England ‘not moving’ on stablecoin ownership limit
• Recent Enforcement Actions – lessons on systems and controls
• US Open Banking Developments

> Read more here

Previous editions

August 2025

Flash Regulatory Update: New UK Safeguarding Regime

The FCA has released Policy Statement PS25/12, outlining significant changes to the UK safeguarding regime coming into force on 7 May 2026.

> Read more here

June 2025

This edition includes updates on:

• FCA multi-firm review of payments and e-money firms
• PSD3 – Final Texts in Sight
• EBA Opinion on PSD2 and MiCA Overlap
• Delay on Non-Bank PSPs’ Access to Central Bank Systems
• Standardised Terms for EU Payment Accounts
• UK Consumer Credit Reform – simplification and modernisation
• PSR APPR consolidated Policy Statement
• FCA’s New Enforcement Guide
• House of Lords Report on Growth and Competitiveness
• Next Stage of UK Crypto Regulation
• PSR Policy Statement on Specific Directions 2 and 3
• PSRs 2017 Update: Farage Termination Changes
• EU and FATF AML List Updates
• UK Payment Services MoU Updated

> Read more here

Spring 2025

This edition includes updates on:

• Abolition of the PSR;
• Upping the ante – FCA to encourage risk-taking in push for growth;
• FCA and PSR digital wallet work highlighted as a competition issue;
• Contactless payment limits changes;
• Quincecare Update – ‘duty of retrieval’ rejected;
• Consumer Duty – multifirm review findings published;
• ECB decision on non-bank PSP access to central bank systems; and
• Eurosystem verification of payee confirmed.

> Read more here

Flash Update – FCA Dear CEO Letter

Our flash update on the FCA’s Dear CEO on its payments portfolio approach.

> Read more here

January 2025

This edition includes updates on:

• The PSR’s five-year strategy and FCA letter to PM
• Open Banking: FCA and PSR next steps
• The FCA’s response to PM on competitiveness
• A Digital Pound blueprint and progress update
• Major incident reporting under PSD2 now repealed
• Q1 dates for your 2025 diary

> Read more here

Winter 2024

This edition includes updates on:

• A vision for the UK payment industry
• Substantive update to FCA perimeter report
• New Payments Architecture consultation
• PSR Dear CEO letter to tech firms
• Updates for crypto / crypto-adjacent firms
• Consumer Duty board report findings and FCA plans

> Read more here

October 2024

This edition includes updates on:

• Buy Now, Pay Later, Regulate Soon (v2.0)
• Slower Faster Payments implementation
• APP scam post-implementation updates
• Interim Regulatory Initiatives Grid published
• Court of Appeal sides with consumers on Motor Finance Commission Disclosures
• PSR seeking feedback on card-acquiring remedies
• FCA findings from multi-firm review of consumer credit firms and non-bank mortgage lenders
• Open Banking coming to America

> Read more here

Payments Consumer Duty multi-firm review

The FCA have published their key findings from the review of implementation of Consumer Duty in payments firms. While this review was focussed on payments firms there is clearly a high level of read across to the FCA's expectations of how the Consumer Duty should be implemented by all types of firm. A summary of the findings can be found here. We have created a table (downloadable) to help evidence your current position against the FCA’s comments and can help you cut through the noise to focus on the aspects applicable to your business and customers.

> Read more here

September 2024

This edition includes updates on:

• Overhaul of the safeguarding regime
• Countdown to APP scam rules
• Update on FCA’s proposals for more public enforcement
• Open Banking implementation roadmap – “full completion” confirmed by CMA
• Expansion of VRPs – PSR proposals confirmed
• Why payments firms should pay attention to DORA
• Consumer Duty good and bad practices update

> Read more here

Summer 2024

This edition includes updates on:

• ECB policy update for European PSPs
• Digital wallets next in the regulatory spotlight
• Further pushback for FCA on plans to publicise enforcement investigations with Lords and FSRC enquiries
• Final push for APP scam reimbursement rules changes
• Focus on Virtual IBANs by the EBA and AMLD6
• Provisional findings of ‘lack of effective card competition’
• Bank of England Paper on innovation in money and payments
• Credit Corner: Motor Finance Discretionary Commission Arrangements
• Operational resilience observations from FCA

> Read more here

April 2024

This edition includes updates on:

• FCA Perimeter Report update: NPA, Open Banking and Access to Cash changes
• The latest on the PSR’s mandatory reimbursement requirement for APP scams: data, reporting and compliance
• High Court considers novel APP fraud “retrieval duty” claim against both sending and receiving PSPs
• FCA anti-greenwashing rule
• Reflections from the PSR’s Head of Supervision and Compliance Monitoring
• NPA – letter from PSR to Pay.UK on delay, investment and expansion
• Design for the Future Entity proposed by JROC
• Update on the ‘FCA priority’ of Big Tech
• Crypto, sanctions and monitoring changes to Financial Crime guidance proposed by FCA
• Dear CEO letter on Motor Finance Discretionary Commission
• FCA Handbook update: Financial difficulty - protections for consumer credit and mortgage borrowers
• PSR Annual Plan and Work Plan published
• Money remittance firms fined £150,000 by FCA on competition grounds

> Read more here

March 2024

This edition includes updates on:

• Longer settlement time to be allowed for suspected APP scams
• Draft SI published on PSP contract termination changes
• Six month deadline for Annex 1 firms' AML review
• 'FCA not focused on technical breaches of Consumer Duty nor acting retrospectively on motor finance'
• FCA to review firms' treatment of customers in vulnerable circumstances
• FCA scrutiny of growing demand for personal guarantees for small business loans (including loans to corporates)
• Greater 'risk-based approach' to be required under UK MLRs
  HMT proposes 'National Payments Vision'

> Read more here

February 2024

This edition includes updates on:

• FCA consultation on new approach to publicising enforcement actions
• Pay.UK's industry solution for APP scams will not be ready for Day 1 of reimbursement requirement
• 'Good and bad practice' for Day 2 Consumer Duty
• FCA data on its financial promotions enforcement
• APPG report on de-banking
• 'Business as usual' approach suggested by Labour's financial plan
• Regulators' approach to cost-benefit analysis and regulatory accountability
• SEPA Instant Euro proposal adopted
• European ruling on scope of e-money
• PSD3/PSR Update: ECON adopts draft reports
• Report on 2023 stocktaking of Big Tech direct financial services provision in the EU
• FCA update on reducing and preventing financial crime
• Bank of England's proposals to enhance Real Time Gross Settlement system

> Read more here

January 2024

This edition includes updates on:

• the Digital Pound and Euro proposals
• Extension of the Special Resolution Regime for "Small Banks"
• FCA push back on the Complaints Commissioner's report on oversight of Premier FX
• Revisions to the PSRs Specific Directions on the Card-acquiring Market
• AML changes: DAML exemptions and high risk third countries
• Our very first Credit Corner on the FCA's work in the motor finance market and BNPL
• Reminder: Consumer Duty a current focus for the FCA

> Read more here

December 2023

This edition includes updates on:

• The FCA's refreshed Regulatory Initiatives Grid
• Final policy statement on APP fraud
• Consultation on Access to Cash
• The PSR's interim report on cross-border interchange fees
• Questions over the UK's proposals for a retail CBDC
• Another speech on the incoming APP fraud proposals
• Open Banking Update: JROC progress and SEPA API
• Dutch consultation on sub-merchant good practices

> Read more here

November 2023

This edition includes updates on the future of payments review; our webinar with the FCA’s Head of Payments and Digital Assets and more.

> Read more here

October 2023

This edition includes updates on the money mule review, BoE and PSR speeches on the status of payments regulation and the future of Open Banking.

> Read more here

September 2023

This edition includes updates on APP fraud, access to cash and the EBA’s mystery shopping exercise.

> Read more here

Summer 2023

This edition includes updates on the Edinburgh Reforms, amendments to the PSRs, credit reform, APP fraud developments and the FCA’s view on Big Tech in finance.

> Read more here

June 2023

This edition covers key publications from the EU (including proposals for PSD3) as well as updates on Open Banking and APP fraud.

> Read more here

May 2023

This edition includes updates on the PSR’s plans for the year, the government’s new fraud strategy and some interesting thoughts from UK Finance on the Call for Evidence on the PSRs.

> Read more here

April 2023

This month’s edition covers FSCS, future planning from the regulators and our response to the PSR’s consultation.

> Read more here

March 2023

This month's edition covers a warning from the FCA on ‘unacceptable’ risks, updates on APP fraud and the regulatory initiative grid.

> Read more here

February 2023

This bumper edition includes key reports on proposals for a Digital Pound, the future of Open Banking and regulation of Buy-Now-Pay-Later, as well as updates on APP Fraud and Strong Customer Authentication.

> Read more here

Open Banking updates – February 2023

This update sets out further details on the recent Open Banking developments and End of Implementation Roadmap Report.

> Read more here

February 2023: A Digital Pound for your thoughts?

Ahead of the next edition of Payment View, we wanted to share our take on the proposals for a digital pound.

> Read more here

January 2023

This edition includes updates on the proposed reform of payments and e-money regulations, Open Banking, APP fraud and updates from our colleagues in Luxembourg.

> Read more here

December 2022

This edition includes the key points from the Edinburgh Reforms as well as an update on the key payments trends of 2022, including the digitisation of payments, APP fraud and the Consumer Duty.

> Read more here

November 2022

This year’s penultimate Payments View includes updates on the FCA’s work on Big Tech, the Consumer Duty and Open Finance, Account-to-Account payments, and the PSR’s next steps on its market review of card fees. We also hear from our Dutch colleagues on recent updates in the Netherlands and are seeking market participants on a new Payments Reviewer product.

> Read more here

October 2022

This edition which includes updates on the next steps for APP fraud and Confirmation of Payee, guidance from the PSR on digitisation and more.

> Read more here

September 2022

This edition includes updates on the development of Open Banking, the FCA’s concerns over BNPL adverts and more.

> Read more here

August 2022

This edition covers the Financial Services and Markets Bill, Consumer Duty, the PSR’s response to the Digital Payments Initiative report and more.

> Read more here

June 2022

This edition covers commentary on HMT’s response to the BNPL consultation, the European Commission’s review of PSD2 and more.

> Read more here

May 2022

This edition covers stablecoins and CBDCs and some things to look out for in the FCA’s regulatory initiatives grid.

> Read more here

April 2022

This edition covers on Innovate Finance’s Global Summit, a session run by APPG on regulating BNPL and much more.

> Read more here

March 2022

This edition covers key developments related to SCA, safeguarding and Russia’s invasion of Ukraine.

> Read more here

February 2022

In this edition we include key developments for payment systems, steps for tackling fraud and in the wider banking and payments market

> Read more here

January 2022

In this edition we include key developments from the end of last year and commentary on the year ahead.

> Read more here

November 2021

Welcome to the first edition of Payments View, the latest addition to our series of informal round-ups of legal and market developments.

> Read more here

Simmons’ Payment resources

Digital Finance - Payments

An overview of the shift to digitisation and current market trends and regulatory issues in the retail banking and finance space. [E-money models (wallets / stored value), SCA and TPP access, e-commerce, partnerships / outsourcing, FCA approach post COVID and Wirecard, crypto / CBDC].

> Watch on demand

Introduction to Payments

An introduction to the basics of payments law focusing on common payment models and the regulatory framework in the UK.

> Watch on demand