The Payments Association (“TPA”) welcomes the opportunity to respond to HM Treasury’s
consultation on Modernising Payment Services Regulation, published on 14 July 2026 and
closing on 6 October 2026. The consultation is the most significant review of the UK’s payment
services and electronic money framework since the Payment Services Regulations 2017
(“PSRs”) and the Electronic Money Regulations 2011 (“EMRs”) were made. It will decide
where regulatory detail sits in future, how tokenised money and AI agents enter the payments
perimeter, and how the next phase of Open Banking is governed and paid for. Our members
have engaged with it accordingly.
This response reflects views expressed by TPA members and industry experts through a
dedicated members’ evidence session held on 15 September 2026, attended by more than 25
members, together with follow-up written submissions, including detailed papers on the
legislative architecture and on prudential risk management at payment and e-money
institutions. TPA’s membership spans banks, payment institutions, e-money institutions, Open
Banking providers, card schemes, acquirers, platforms, technology providers and their legal
and other advisers, and holds a correspondingly diverse range of views. This response
therefore cannot and does not claim to represent the position of every member on every
question. Where members hold coherent but different views, most notably on senior manager
accountability and on Open Banking pricing, we set out both.
We are grateful to the contributors to this response, which has been drafted by Robert
Courtneidge and Natasha Healy on behalf of TPA’s Policy team. We would also like to thank
HM Treasury for its continuing engagement with industry. We hope this response supports the
shared goal of ensuring the UK remains the best place in the world for payments businesses
to establish, invest and grow.
The consultation asks 42 questions across Chapters 2 to 4. We answer each of them below,
in order and in HM Treasury’s own wording, grouped under the consultation’s chapter and
section headings. Where our members did not have specific evidence on a question, we say
so and give a shorter answer rather than speculate.
The Payments Association is content for HM Treasury to identify it by name as a respondent
to this consultation.
