
Regulation Roadmap Q3
TPA’s Q3 UK Payments Regulation Roadmap explains the key UK and international regulatory developments affecting payment firms over the coming years.
13 November 2025
by Payments Intelligence
The UK has long been a beacon for financial innovation. Its rich ecosystem of fintechs, payment providers, and regulatory expertise has made it a global benchmark for digital finance. Yet, that leadership is slipping. A combination of heavier regulation, shifting tax structures, and lack of urgency on open banking and stablecoin frameworks has slowed momentum at precisely the moment global competition is accelerating.
In recent years, fintechs have increasingly struggled with scaling, compliance costs, and diminishing investor confidence. While new initiatives such as the FCA’s and PRA’s Scale-Up Unit are welcome, broader policy reform is urgently needed. For the UK to retain its influence, the government must prioritise regulatory clarity, competitive taxation, and targeted innovation incentives that support the full payments value chain — from start-ups and PSPs to major banks and merchants.
Expect greater scrutiny of regulatory compliance and capital resilience as the government reassesses the balance between innovation and consumer protection
Prepare for higher operating costs as reimbursement requirements take hold and open banking remains slow to mature across e-commerce use cases.
Anticipate closer involvement in stablecoin and digital asset pilots as regulators seek practical input on redemption models and systemic safeguards.
Look for gradual expansion of Variable Recurring Payments beyond utilities and telecoms, opening opportunities to streamline checkout and recurring billing.
Long recognised as a global hub for financial services, the UK government’s pursuit of economic growth naturally turns attention to the fintech sector.
Yet increasing regulatory complexity, rising National Insurance contributions, and the dilution of start-up investment incentives are constraining momentum across financial services. The sharp rise in e-money and payment institutions withdrawing their FCA licences underscores these pressures: an average of 23 firms exited annually between 2018 and 2021, compared with 138 in 2022 and 139 in 2023.
These challenges are not insurmountable. Swift progress on stablecoin and open banking regulation would provide firms with the clarity needed to innovate confidently. At the same time, reviewing the overall regulatory load on fintechs and safeguarding tax incentives for early-stage employees could help restore a more competitive growth environment.
Sound policy is especially vital as the UK’s global standing comes under strain. According to Innovate Finance, the United Arab Emirates (UAE) surpassed the UK to become the world’s second-largest fintech market in the first half of 2025. Although this was partly driven by Binance’s $2 billion raise, the UAE’s broader appeal—light-touch regulation, a low tax regime, and a fast-expanding economy—cannot be ignored.
The UK retains distinct strengths in talent, infrastructure, and institutional credibility. The degree to which fintechs can capitalise on these advantages will ultimately depend on the direction and decisiveness of government policy.
Sustained growth in the UK fintech and payments ecosystem will depend on a regulatory environment that enables innovation rather than constrains it. While the UK continues to attract talent and capital, policy uncertainty and uneven regulatory progress are beginning to erode its competitive edge.
To restore confidence and stimulate long-term investment, the government should focus on three interlinked priorities: establishing a proportionate and internationally aligned framework for stablecoins; ensuring regulation supports rather than deters investment; and accelerating open banking adoption to unlock the next wave of payments innovation.
The FCA has taken steps towards establishing a safe and effective stablecoin regime. The industry has welcomed this; however, many firms believe the proposals in their current form are too complex and risk being less supportive of growth than the frameworks emerging in other leading jurisdictions, particularly the US
The banking community welcomes the move towards treating stablecoins as “money-like” instruments with clear backing and near real-time redemption, which would help build trust and confidence. However, there is concern that the overall regulatory burden could discourage UK-based issuers from launching at all.
This challenge is heightened by the fact that stablecoins issued overseas will still be able to circulate in the UK. Without proportionate, innovation-friendly rules that allow domestic issuers to compete, there is a risk that investment and new products are developed offshore and merely distributed into the UK, rather than being built and scaled here.
To support growth, the government and regulators will need to ensure the regime is internationally competitive, avoids excessive prescriptiveness, and is aligned with the broader ambition for the UK to be at the forefront of digital asset innovation. Accelerating clarity on the regulatory framework, while maintaining appropriate safeguards, would help unlock the economic and technological benefits stablecoins can bring, particularly in payments, settlement, and cross-border transactions.
A whitepaper from TPA’s Digital Currency Working Group recommends the following:
Additionally, the Bank of England has proposed capping stablecoin holdings at £20,000 for individuals and £10 million for businesses. These limits, which have no equivalent in the US or EU regulations, have drawn criticism from the industry.
In an article by the Financial Times, Riccardo Tordera-Ricchi, director of policy and government relations at The Payments Association, says, “Limits make no sense. Just as there are no limits on cash, bank accounts, or e-money, there is no reason beyond scepticism to impose limits on stablecoin ownership.”
In a consultation paper published on 10 November 2025, the Bank announced that retailers and cryptocurrency exchanges could be exempt from the £10 million limit on business transactions.
Although macroeconomic headwinds have deterred investment in fintechs globally, several factors are specifically inhibiting fintech growth in the UK.
A key barrier to new fintech entrants is the Payment System Regulator’s (PSR) mandatory reimbursement requirement, which has raised the cost and complexity of market entry. While this issue was highlighted during consultation, its real-world impact now warrants scrutiny.
There is a growing perception among investors that capital deployed into early-stage UK fintechs risks being absorbed by fraud reimbursement rather than growth, which appears to be dampening investment appetite.
Investment (US$ billion)
Chart: Payments Intelligence
For established but early-stage fintechs, another pressure point is the changing tax treatment of enterprise management incentive (EMI) share schemes. These schemes have traditionally been a critical tool for attracting and retaining talent in high-growth firms, offering employees a preferential 10% rate of Capital Gains Tax on exercised options.
The rate has already risen to 14% and is expected to increase further to 18% from 6 April 2026. Weakening this tax incentive erodes one of the key advantages that has supported the fintech ecosystem to date. Combined with increased National Insurance contributions and compliance costs of the new PSR regime, the environment for starting and scaling fintechs in the UK has become more challenging.
The government is starting to take action to support growing businesses. In October 2025, the FCA and Prudential Regulation Authority (PRA) announced a joint Scale-Up Unit to “provide a dedicated point of contact to tackle some of the challenges scaling firms face.”
The unit will initially support banks and building societies, insurers, and FCA solo-regulated firms, providing support for:
More details are expected in Spring 2026.
Open banking enables third-party financial service providers to access customer financial information from traditional banks via an application programming interface (API). Fintechs, as third-party financial service providers, benefit from open banking in several ways:
The government can pressure regulators to accelerate the availability of Variable Recurring Payments (VRP) for e-commerce merchants, as it is currently restricted to government, financial institutions and regulated utilities and telecoms.
More broadly, the government can encourage the adoption of open banking. A survey of 500 merchants run by Payments Intelligence and Opinium found 31% of merchants considered a lack of consumer demand or awareness of open banking to be the biggest barrier to adoption. The government can help with consumer education, as well as encourage the industry to have a consistent brand mark to help increase consumer awareness levels.
For senior leaders in payments, the direction of travel is clear: stablecoins and digital asset regulation are moving from theoretical to operational. The decisions taken now will shape competitiveness over the next five years.
The message for leaders is simple: stablecoins are no longer peripheral. Regulation is creating the certainty institutions need to integrate them into payment and treasury architecture. Those who act now will be best positioned to shape the next phase of digital payments.

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