UK National Payments Vision is issued after lengthy debate

November 2024
National Payments Vision

October 2024
National Payments Vision

4
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ISBN 978-1-917151-61-0 PU 3468

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Contents
Ministerial Foreword 6
Executive Summary 8
Chapter 1 Introduction 11
Chapter 2 Strengthening the foundations of today 17
Chapter 3 Building for tomorrow – driving innovation, facilitating
competition and ensuring security 26
Chapter 4 Implementing the National Payments Vision 38

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Ministerial Foreword
The government’s central mission is to grow the economy – to restore
stability and improve living standards across the country.
Every strong economy relies on effective payments. Payment systems
and providers allow money to flow through the economy, enabling the
exchange of value on which economic activity relies.
Almost 50 billion payments were made in the UK last year by
consumers and businesses. That’s around 1500 transactions every
second. But while most of us will keep a close eye on what we’re
spending, we rarely need to give a second thought to how that
payment is made. And that’s the way it should be. Payments – whether
by cash, cheque, card or bank transfer – should just work.
But there is a lot that goes on behind the scenes to deliver a seamless
and trusted experience to consumers. The underlying infrastructure
must be kept secure and resilient, with consumers protected if
something goes wrong. It is vital that payment providers are
incentivised to innovate to provide efficient and effective products and
services.
Recent years have seen huge changes in the way we pay, with the UK
often leading the way globally. Mobile banking, contactless payments
and digital wallets, for example, have dramatically increased
convenience. And significant further technological developments are
now on the horizon that offer huge potential for further innovation.
These new technologies are likely to transform the way we pay for
goods and services. I am determined to ensure that the UK is in a
strong position to seize these opportunities – doing so will benefit users
of these payment systems as well innovative firms across the financial
services sector.
The National Payments Vision therefore sets out the government’s
ambitions for this vital sector, to achieve a trusted, world-leading
payments ecosystem delivered on next generation technology, where
consumers and businesses have a choice of payment methods to meet
their needs.
Alongside an articulation of this Vision, the government is taking a
number of decisive steps to achieve that ambition. This includes a
package of actions to cut through the current regulatory congestion
facing the sector, and steering the approach to vital upgrades that are
needed to the UK’s underlying payments infrastructure. To achieve this
Vision, it is imperative that the government, regulators and the sector
work collaboratively. The government is therefore establishing the

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Payments Vision Delivery Committee – a senior cross-authority group,
chaired by HM Treasury, and with a clear voice for stakeholders –
responsible for delivering a clear forward plan for the sector, in line with
the Vision.
A world-leading payments ecosystem is a critical underpinning to this
government’s central growth mission and its ambition to deliver world-
leading rates of GDP growth. This publication sets out our goals for UK
payments, and charts a path for achieving these.
Tulip Siddiq MP
Economic Secretary to the Treasury

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Executive Summary
The National Payments Vision outlines the government’s ambitions for
bolstering the UK’s payments sector to deliver economic growth. It
charts a clear path for government, regulators and the sector towards a
trusted, world-leading payments ecosystem delivered on next
generation technology, where consumers and businesses have a
choice of payment methods to meet their needs.
The Vision takes action to strengthen the foundations of today’s
ecosystem and steer future activity to drive innovation, facilitate
competition and ensure security. In doing so, the Vision addresses
findings from the independent Future of Payments Review 2023, led by
Joe Garner, and extensive stakeholder feedback.
UK context
The UK has long been a global leader in payments, with a strong
banking, cards and digital wallets environment and a well-established
regulatory framework.
The payments landscape has evolved significantly in recent years – and
payments are increasingly digital. Looking ahead, developments in
next-generation technologies like distributed ledger technologies and
Artificial Intelligence as well as enhanced data sharing have potential to
fundamentally alter the ecosystem. The UK must act quickly to seize the
opportunities of the future, or risk falling behind international peers.
The Garner Review challenged government to set a strategic vision for
UK payments. The government’s response is clear – a world-leading
ecosystem must ensure trusted payments, delivered on next-
generation technology, with more choice for consumers and
businesses.
Strengthening the foundations of today
The regulatory framework must be clear, predictable and
proportionate. The Prime Minister has been clear that regulation
should support growth and unlock investment – this requires our
regulators to coordinate better to manage their collective impact on the
sector. To support this, the government has outlined its priorities for UK
payments through a joint remit letter to the FCA and PSR and
welcomes the regulators’ commitment to revise their existing
memorandum of understanding on cooperation in relation to
payments regulation.
Resilient infrastructure that supports innovation is a pre-requisite to a
healthy ecosystem and is essential for trust, but upgrading the UK’s

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retail payments infrastructure has been slow and challenging. The
government has considered carefully the role of the New Payments
Architecture programme and concluded that a more agile and flexible
approach to delivering the UK’s infrastructure needs is required to
ensure the UK is primed to seize the opportunities of next generation
technologies. The Vision sets out that the newly established Payments
Vision Delivery Committee will, through work led by the Bank of
England and PSR, clarify the upgrades required to the existing Faster
Payments System, assess longer-term requirements and the
appropriate funding and governance arrangements needed to deliver
this – including proposals to reform Pay.UK.
Building for tomorrow – driving innovation, facilitating competition and
ensuring security
The National Payments Vision also outlines three key pillars designed to
guide future activity – innovation, competition and security. In line
with these pillars, government has provided direction on priority
initiatives in the retail payments arena, in particular Open Banking and
tackling fraud.
It is crucial that seamless account-to-account payments – enabling
consumers to pay for goods and services in shops and online directly
from their bank account – are developed. This will provide greater
choice to consumers and merchants in how they make and receive
payments. Open Banking has a vital role to play in delivering this. The
Vision therefore clarifies regulatory responsibilities for Open Banking,
transitioning away from current arrangements to the FCA acting as the
UK’s regulator in the future, ensuring effective engagement with other
authorities as needed. This will support the pace of progress on core
activities to agree a sustainable commercial model and consumer
protections.
Reflecting the need to consider a range of innovations in this dynamic
landscape, the Vision sets out the government’s commitment to
explore a potential retail Central Bank Digital Currency, the digital
pound. No decision has been taken on whether to launch a digital
pound. The government commits that any decision to proceed would
be accompanied by the introduction of primary legislation, which
would guarantee users’ privacy and control of their money. Regardless
of the final decision, the work will support private innovation and
deepen the expertise of UK public authorities.
The Vision outlines the continued need to maintain high standards of
consumer protection and ensure people and businesses can make
payments efficiently and safely. To further build the effectiveness of
payments fraud regulation, the FCA will lead work to manage existing
overlaps between itself and the PSR, and the PSR has committed to an
independent post implementation review of the authorised push

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payment fraud reimbursement rules, after 12 months. The government
also recognises the role that the technology and telecommunications
sectors play in tackling authorised push payment fraud.
Next steps – Implementing the National Payments Vision
Delivering this Vision requires collaboration across the entire ecosystem
– government, regulators, financial services providers, merchants and
consumer representatives. The government is therefore establishing
the Payments Vision Delivery Committee to drive next steps,
supported by an engagement group comprised of varied
representatives from across the sector. This partnership between the
public and private sector will be key to achieving a world-leading
payments sector that boosts economic growth.

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Chapter 1
Introduction
1.1 Growth is the government’s central mission, and its ambition is to
restore economic stability, increase investment, and reform the
economy to drive up prosperity and living standards across the UK.
1.2 The financial services sector has a central role in delivering this
mission, reflecting its key position as both an enabler and driver of
growth. The sector plays a crucial part in unlocking growth in the
real economy. By supporting consumers and businesses across the
country, it underpins the stable economic environment necessary
for sustainable growth and plays a vital role in allocating capital to
the productive investment necessary to unlock growth across the
economy.
1.3 Payments are a fundamental component of a thriving financial
sector. The ability to make and receive payments is essential to our
daily lives, and underpins commerce, trade and indeed all economic
activity – with 48.1 billion transactions in the UK last year1 alone. In
addition to acting as an enabler for the wider economy, the
payments sector is in itself an important source of growth – at the
heart of a dynamic and innovative financial services sector, and the
source of many high-skilled jobs.
1.4 The UK’s payments landscape is broad and diverse. It encompasses
retail payments made by individuals and businesses (typically high
in volume and low in value), as well as wholesale payments
between financial institutions and with the Bank of England
(typically high in value but much lower in volume).
1.5 This landscape has evolved significantly in recent years, in part due
to legislative and regulatory initiatives designed to support
competition, but also in light of wider technological innovation and
evolving user preferences. Cash remains important and the
government is committed to protecting access, with the Financial
Conduct Authority’s new regime being vital in ensuring that all
members of society can pay for essential goods and services in a
way that suits their needs.
1
See UK Finance’s Payments Market Report 2024 (p. 5):
https://www.ukfinance.org.uk/system/files/2024-
07/Summary%20UK%20Payment%20Markets%202024.pdf

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1.6 However, it is clear that payments – and money – are becoming
increasingly digital. Contactless payments have increased from 3%
of all transactions in 2015 to 38% in 2023, when there were 18.3
billion transactions in total. This is in part due to the rapid adoption
of digital wallets, with ‘Big Tech’ entering the payments arena.
People and businesses in the UK are also increasingly making use of
Open Banking to make payments by bank transfer, with 11 million
current users of Open Banking services in the UK.
1.7 This change shows no signs of slowing down. The UK, alongside
other advanced economies, is at a technological inflection point –
there are multiple significant technological advances which could
fundamentally alter the way that payments are made, processed
and received.
1.8 We see this potential in pioneering developments being explored
by governments, regulatory authorities and financial sectors both
here and around the world, aiming to understand and reap the
benefits of ‘next generation’ technologies. These include distributed
ledger technologies (DLT), such as blockchain and the associated
‘tokenisation’ of assets, and initiatives relating to central bank
digital currencies, stablecoins and the Regulated Liability Network2.
The innovation, efficiency and economic benefit such
developments could bring is potentially transformational.
1.9 The use of Artificial Intelligence also continues to rise across the
sector, with over 91% of firms in the UK using it to enhance back-
office functions and protect customers’ accounts from fraud3.
Additionally, the government shares the excitement of the sector
about the opportunities to innovate and increase efficiencies by
unleashing the power of data – in particular through the secure
sharing of customer data under ‘smart data’ schemes, which
government is supporting through measures in the Data (Use and
Access) Bill.
1.10 Taken together, these next-generation technologies and
innovations have the potential to change the payments landscape
significantly. It is likely that payments become increasingly
automated and embedded within our daily activities without the
need for physical transactions. While this presents opportunities, it
also throws up a range of new policy considerations for the sector.
2 The Regulated Liability Network (RLN) is an industry-led initiative positioned as a
financial market infrastructure (FMI), operating a shared ledger with central bank
money, commercial bank money and electronic money on the same network.
3 From UK Finance/Oliver Wyman’s The Impact of AI in Financial Services (p. 2):
11/The%20impact%20of%20AI%20in%20financial%20services.pdf

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1.11 Looking across the world, there is also ample evidence of innovation
in retail payments being delivered right now, using the best of
today’s technology. Examples include the successful development
of interbank payment methods, such as by Brazil’s PIX service or
Sweden’s Swish app. These innovations can offer greater choice
and competition in the way that payments are made to the benefit
of consumers and businesses.
1.12 As policymakers, it is incumbent on the government and regulatory
authorities to work collaboratively with the financial sector to
ensure that the UK is ready and able to seize the benefits – and
manage the risks – of technological advances, and ensure
consumers and businesses are served well. Work is already
underway in this area, for example reflected in the Bank of
England’s recent Discussion Paper on Innovation in Money and
Payments4.
1.13 The government is committed to the future success of the UK’s
payments sector given its importance to the functioning and
growth of the UK economy. The UK has long been a global leader in
payments. We were one of the first countries to establish a system
for near instant digital payments with the launch of Faster
Payments System in 2008, and the UK pioneered Open Banking in
2016.
1.14 However, a finding of last year’s Garner Review on the Future of
Payments was that the UK is at risk of falling behind international
peers, in part due to a lack of overall strategic direction. Providing
this direction is particularly important now, given the technological
advances on the horizon and as other financial centres also look to
seize the opportunities of the future. There are therefore important
choices to make about where to focus investment.
Garner Review on Future of Payments
1.15 The independent Future of Payments Review 2023, led by Joe
Garner, provided recommendations on the steps needed to
successfully deliver world-leading retail payments in the UK.
1.16 The Garner Review highlighted many positives for the UK payments
sector to build on, including our strong banking, cards and digital
wallets environment and well-established regulatory framework. It
also provided ten recommendations designed to improve the
consumer experience, unlock Open Banking and enhance
4
See here: https://www.bankofengland.co.uk/paper/2024/dp/the-boes-approach-to-
innovation-in-money-and-payments

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alignment between the different authorities that oversee this
sector.
1.17 The Review found that, while the UK has historically been a world
leader, recent years have seen an absence of clear and coordinated
leadership, creating a congested landscape as industry and
regulators seek to keep pace with the evolving technological
environment through well-intentioned, but sometimes isolated and
conflicting initiatives. Therefore, its primary recommendation was
for government to set strategic direction for UK payments, guiding
regulatory and industry activity to reduce congestion in the current
landscape and free-up capacity for innovation.
1.18 The government welcomes the insights and recommendations
provided by the Garner Review in its assessment of the current
landscape. This document sets out actions the government is
taking in line with the Review’s findings.
A clearer ambition for UK payments
1.19 While our historical strengths have endured, maintaining and
enhancing the UK’s success in financial services, including
payments, requires active steps to seize the growth opportunities of
the future. Through this Vision, the government is providing the
strategic direction that the Garner Review called for and is taking
forward a package of actions to unlock innovation and growth, and
deliver the next generation of UK payments.
1.20 The National Payments Vision is intended to provide clarity and
long-term direction to this critical sector, supporting the
prioritisation of today’s activity and enabling focus on the
innovation and investment required to support the UK’s economic
growth and position as a world leader in payments.
1.21 The payments sector is facing an inflection point, domestically and
internationally. The pace of technological advancement is rapid,
and it is too early to determine exactly what the future landscape
will look like. However, emerging initiatives have the potential to
fundamentally alter the current ecosystem.
1.22 The government has therefore taken a principles-based approach
to this Vision. The first section outlines this overarching Vision and
the framework for delivering it. This applies to the entirety of the
payments landscape – setting strategic expectations and priorities
that the future landscape must deliver, regardless of which method
of payment is being used and irrespective of whether the payment
is domestic or cross-border, retail or wholesale.
1.23 The second section sets out actions the government is taking in the
short term, in order to strengthen the foundations needed to

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deliver this Vision. The third section outlines early actions to deliver
on the three pillars of the government’s vision: to drive innovation,
facilitate competition and ensure security. Finally, section four
outlines the next steps to deliver a Payments Forward Plan and
implement this Vision. This includes a mechanism to support close
collaboration between the government, regulators and broad
stakeholder landscape, to ensure these ambitions for the future
payments ecosystem can be delivered.
1.24 The actions set out in this Vision are predominantly focused on
retail payments, reflecting the focus of the Garner Review. This does
not detract from important activity to enhance wholesale
payments, which crucially underpin the payments ecosystem. This
includes the Bank of England’s RTGS Renewal programme and its
Future Roadmap, and the Bank of England omnibus account
available to support ongoing industry innovation. The government
welcomes the Bank of England’s ongoing consideration of its
approach to innovation in wholesale payments, as outlined in its
July 2024 Discussion Paper5
.
1.25 In producing this Vision, government has engaged extensively
across the broad payments landscape, building on feedback to the
Garner Review, including the Review’s public Call for Input. It has
worked closely with the independent regulators – the Bank of
England, Financial Conduct Authority and Payments Systems
Regulator – who, working together, oversee this sector and lead
many key initiatives.
5
See here: https://www.bankofengland.co.uk/paper/2024/dp/the-boes-approach-to-
innovation-in-money-and-payments

16
A trusted, world-leading payments
ecosystem delivered on next
generation technology, where
consumers and businesses have a
choice of payment methods to meet
their needs.
To achieve this, the ecosystem must be underpinned by strong foundations:
• The regulatory framework for payments must be clear, predictable and
proportionate. Regulators must coordinate well to support each other’s
activities and manage their collective impact on regulated entities. The
regulators have a critical role in implementing the government’s vision and
ensuring a world-leading payments ecosystem.
• Resilient infrastructure is a pre-requisite to a healthy ecosystem and is
essential for trust. To deliver world-leading payments, the underpinning
infrastructure must be both resilient and support innovation. The resilience and
functionality of today’s infrastructure must be secured, while investing in the
technology of the future.
Building from this, three pillars should guide activity across the ecosystem:
• Innovation must be at the heart of UK payments, delivering solutions to
enhance the lives of consumers, and support the growth of UK businesses and
the economy. Innovation is fundamental to unlocking the benefits of next
generation technology. It should be led by the market, within clear parameters
set by regulators. Payments innovation should benefit us all, including those
with varied needs when making or receiving payments.
• Competition is key to enabling a diverse ecosystem, providing individuals and
businesses with choice in how to make and receive payments, and spurring
innovation across the landscape. The provision of payment-related services
should be underpinned by sustainable commercial arrangements, incentivising
ongoing investment in these services and the sector more widely.
• Security – Both the safety of our systems and protections for those making
and receiving payments are critical. Payments are global in nature and an
international outlook is therefore important – the government encourages
efforts to boost cross-border activity and international interoperability but not
at the expense of consumer protection or financial stability.
The government’s vision

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Chapter 2
Strengthening the
foundations of today
2.1 The government’s vision is for a trusted, world-leading payments
ecosystem delivered on next generation technology, where
consumers and businesses have a choice of payment methods to
meet their needs. To achieve this, the UK’s payments ecosystem
must have strong foundations – providing the right conditions to
support investment, enable innovation and stimulate growth now
and into the future.
2.2 First, the regulatory framework must be clear, predictable and
proportionate. The UK regulators have a critical role to play in
achieving the government’s vision and ensuring the system is set up
for success. As part of this, regulators need to coordinate effectively,
considering their collective impact on regulated entities.
2.3 Second, the underlying infrastructure through which payments are
made and processed must be resilient and reliable. Above all else,
payments must work – consumers and businesses need to have
trust that their payments will be processed safely and smoothly
whenever they need. But it is also vital that the underlying
infrastructure enables innovation, and allows the UK to seize the
opportunities of next generation technology.
2.4 The government is taking action to strengthen these foundations to
ensure the UK can take the necessary steps to deliver world-leading
payments. In line with the findings of the Garner Review, the
following sections outline actions to address congestion in the
regulatory landscape for payments and to steer the approach to the
renewal of domestic retail payments infrastructure.
Strengthening coordination and addressing congestion in the
regulatory landscape
2.5 The Prime Minister has been clear that regulation should support
growth and unlock investment. The strength of the UK’s regulatory
environment is central to our leading role in financial services
globally, and the regulatory environment is a core pillar of the
Financial Services Growth and Competitiveness Strategy. Ensuring a
robust, transparent and agile regulatory framework that supports
growth and competitiveness while maintaining financial stability,

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market integrity and consumer protection is central to growth.
Payments regulation must be clear, predictable and proportionate
to ensure the strength of the sector and support innovation.
2.6 The Garner Review highlighted the UK’s relative strength in the
sophistication of its financial services regulators and noted that we
benefit from a well-developed regulated environment. The Financial
Conduct Authority, the Bank of England and the Payment Systems
Regulator have collective regulatory oversight of the UK’s payments
sector, but with differing mandates – each authority has its own
statutory objectives and regulates different aspects of payments
activity.
2.7 However, the Review found that the payments landscape suffers
significant regulatory congestion, with a large programme of
initiatives – stemming from the government, the three regulators
and industry – resulting in a significant burden on the sector. Each
initiative has individual merit, with some intended to alleviate
regulatory burden in the longer term, but the government is
concerned that the collective impact is hampering the sector’s
capacity for innovation and growth.
2.8 The Review identified two key contributing factors to this
congestion. First a lack of a central and strategic vision to enable an
effective prioritisation of initiatives – which the government is now
providing through this Vision. Second, that coordination between
the regulators needs to be improved.
2.9 Government is not convinced that introducing a numeric target for
reducing regulatory burdens, as was recommended in the Garner
Review, is viable. However, we recognise the critique, and are taking
decisive steps to enhance regulatory coordination and address
congestion in the payments landscape.
Payments remit letter
2.10 As part of a package of measures to enhance regulatory
coordination, the Garner Review recommended that government
issue new remit letters to the regulators to provide a strategic steer
on the government’s priorities for payments and drive closer
alignment of policy objectives. Remit letters provide the opportunity
to make recommendations about aspects of the government’s
economic policy which the regulators should have regard to when
furthering their statutory objectives (among other things). The
government has issued letters to the FCA and Prudential Regulation
Committee (PRC) of the Bank of England, setting out that the FCA
and PRC should have regard to the government’s policy towards the
financial services sector, where the government’s top priority is to
promote its growth and international competitiveness.

19
2.11 Alongside this, the government has issued a first of its kind
payments remit letter jointly to the FCA and PSR, providing
recommendations relating to the government’s priorities for the
UK’s payments sector, in line with the National Payments Vision. The
payments remit letter reflects the critical role of the sector in
supporting economic growth, and calls for enhanced coordination
between authorities, in line with statutory requirements, to ensure
its continued success. The payments remit letter is also copied to
the Bank of England and Prudential Regulation Authority.
2.12 The key priorities highlighted in the payments remit letter are:
• Enhancing coordination to address congestion in the
regulatory landscape. The government is taking several actions
to support strengthened coordination between authorities to
support the growth of the payments sector, and is clear that
addressing congestion in the landscape is vital to ensure capacity
for the innovation required to deliver world-leading payments
into the future. In this regard, the payments remit letter
welcomes the FCA’s commitment to lead work on enhancing the
management of overlaps between the FCA and PSR’s exercise of
their functions, particularly in relation to fraud policy.
• Supporting the development of Open Banking. In line with its
vision to increase choice in payment methods across the
ecosystem, the government calls on the FCA and PSR to consider
its commitment to developing Open Banking to drive delivery of
seamless account-to-account payments. In this regard, the
government has asked the FCA to be the UK’s regulator for Open
Banking, while ensuring effective engagement with other
relevant authorities, including cooperating with the PSR on
matters related to designated payment systems.
• Ensuring high standards of consumer protection and that
people and businesses can make payments efficiently and
safely. In particular, reducing levels of fraud will support
competitiveness and growth by ensuring consumers and
businesses have trust in our financial services sector. The
government therefore welcomes upcoming work from the
regulators to examine data sharing initiatives across the financial
services sector. This issue is also one where clearer delineation of
responsibilities between the FCA and PSR is welcome. Regarding
the new authorised push payment fraud reimbursement rules,
the government welcomes the PSR’s commitment to a publish
an independent review of its rules after they have been in place
for 12 months.
• Driving an agile and flexible approach to delivering the UK’s
retail payments infrastructure needs. This includes work to

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examine and refresh the requirements for the UK’s retail
infrastructure and the governance and funding arrangements
needed to deliver this.
2.13 The payments remit letter welcomes the FCA and PSR’s
commitment to drive forward action to achieve the government’s
vision through participation in the Payments Vision Delivery
Committee. Further detail on the Committee is provided in section
four of this document.
Memorandum of Understanding for payments cooperation
2.13 Under statute, the Bank of England, FCA, PRA and PSR are required
to coordinate the exercise of their specified functions relevant to
payments and maintain a Memorandum of Understanding (MoU)
outlining (among other things) how they will fulfil that duty.
2.14 These existing mechanisms to support coordination between
regulators should be strengthened to ensure a more efficient and
joined-up approach to engaging with the sector, particularly smaller
firms. The government agrees with the Garner Review
recommendation for the Bank of England, PRA, FCA and PSR to
revise their existing MoU on cooperation in relation to the regulation
of payment systems, and welcomes their commitment to do this by
Q2 2025.
2.15 In undertaking this revision, the government expects the regulators
to consider their collective impact on regulated firms and how this
impact might be reduced, including through streamlining requests
for information to minimise duplication. This is particularly relevant
for smaller firms with less resource to manage regulatory requests,
as highlighted by the Garner Review recommendation to consider
the application of key regulations to the fintech sector.
2.16 In preparing their response to the payments remit letter, the
government has asked the regulators to clearly outline actions
taken to improve coordination and minimise overlaps, for example
by clarifying regulatory responsibilities on specific issues. The
regulators should regularly consider these arrangements through
their annual reviews of the MoU.
Delivering world-leading payments infrastructure
2.17 The Garner Review outlined that “a world leading payments
environment is vital for a world leading economy and a healthy
society. The economy cannot grow without the payments
infrastructure to support it”. The government agrees with this
assessment, recognising the critical bearing that payments have on
the UK’s economy, and in supporting future innovation.

21
2.18 Predicting the landing-zone for the future of payments, domestically
or globally, is not easy. The number of developments and potential
opportunities over the horizon are numerous – for example from
central bank digital currencies (CBDC), the Regulated Liability
Network (RLN) and stablecoins. The UK needs to be ready and have
capacity for tomorrow’s innovation, yet there also remains a specific
and critical need to develop the UK’s retail payments infrastructure
beyond its current capabilities today.
2.19 The UK’s Faster Payments System (FPS), developed in 2008, was one
of the world’s first instant payment systems, making transfers
directly between individuals’ bank accounts, predominantly through
internet banking . Although the UK’s retail payments landscape
remains strongly comprised of card-based payments, the level of
growth in Faster Payments is steadily rising, reaching 4.9 billion
payments in 2023 and now comprising 10% of all payments made in
the UK6
.
2.20 Looking across the globe to countries such as Sweden and Brazil, it
is clear, however, that there is far greater potential and innovation
that can now be harnessed from account-to-account payments. For
customers, this could translate into the paying for goods or services
in a shop or online via mobile phone numbers or QR codes. For
merchants, they may potentially benefit from cost savings driven by
having a wider variety of payment options. Meanwhile, the UK’s
pioneering fintech sector could be ideally placed to deliver the next
wave of innovation in payments, making the most of better and
more innovative account-to-account payments infrastructure in the
UK.
2.21 Upgrading the UK’s retail infrastructure is essential, but it has been
slow, with the project to upgrade it – the ‘new payments
architecture’ (NPA) – commencing in 2017. The Garner Review
received many representations about the NPA. While written
comments were mixed, the report described the views of
contributors at interview as “forthright” and “emotive”, concluding
“that confidence in a timely and successful delivery of NPA appears
variable at best”.
2.22 Evidence taken during and since the Garner Review has not only
been critical of the time and difficulty of making progress with the
NPA. It has also surfaced more fundamental issues around the
future of the UK’s infrastructure needs and capability, than just the
NPA programme itself:
6
See UK Finance’s Payments Markets Summary (p. 5):

22
• This included, in particular, concerns with the governance
model for the UK’s retail payments infrastructure and the
respective roles of the payment systems operator (Pay.UK),
the regulators, and industry.
• Concern was also raised about the risk of consuming the
sector’s energy on a new payments architecture for retail
payments while there remains uncertainty around what ‘the
next generation of payments’ looks like and the implications
for the UK’s marketplace.
• Questions were also raised about how the UK’s infrastructure
choices would support the work of the G20 and G7 on
improving efficiencies in cross-border payments, and the
extent to which the UK would be minded to interlink with
other Faster Payment Systems.
2.23 These reflections, combined with the significant technological
developments on the horizon, have led the government to conclude
that decisions around the UK’s retail payments infrastructure are
increasingly complex and strategic. It has become clear that the
government needs to have greater involvement, at least in the short
to medium term, in future decisions relating to payments
infrastructure than it has had in the past. In turn, the UK’s regulators
and industry stakeholders will need to be highly engaged to help
ensure the right choices are made.
The next steps for the UK’s retail infrastructure
2.24 There is broad agreement that timely and significant investment is
needed in the UK’s retail payments infrastructure to ensure it is
resilient and better enables innovation and competition. The
question is how best to deliver this while ensuring the sector still has
space to innovate and invest in tomorrow’s innovation.
2.25 The government considers that a more agile and flexible
approach to delivering the UK’s infrastructure needs is required,
and has some reservations about a full and comprehensive overhaul
of today’s infrastructure at the current juncture. A more pragmatic
approach would develop the UK’s retail payments infrastructure in a
way that is better able to take account of future developments and
the possibilities posed by innovation, particularly distributed ledger
technology.
2.26 Consideration should also be given to the importance of
interoperability between different systems, both domestically and
internationally, noting the benefits offered here by upgrading to the
latest messaging standards (ISO20022). Any decisions relating to
interoperability will need to be made carefully, while maintaining
the domestic security of our systems at all costs.

23
2.27 Notably, a process is already underway to advance the UK’s
infrastructure in a way that may offer greater agility. The Payment
Systems Regulator publicly wrote to Pay.UK in a letter dated 11 April
2024, requesting proposals from Pay.UK to explore further
investment in its current infrastructure arrangements to improve
resilience and support greater innovation. The government
considers this intervention to be prudent.
Setting direction and ensuring the right arrangements for delivery
2.28 In addition to technological upgrades to the system, the
government considers that the effective delivery of the UK’s
retail payments infrastructure now and through time requires a
strong and effective payment systems operator, and the current
set of organisational arrangements could be improved. The
government has heard frustration at Pay.UK’s ability to work at pace
to deliver programme change and to set direction, both from the
organisation itself as well as various market participants. This
tension needs to be resolved with a more effective set of
arrangements put in place to enable swifter and more strategic
decision-making while still reflecting the needs of all stakeholders to
ensure that payment systems operate for the benefit of end users as
well as the wider economy. This is likely to require more effective
governance arrangements and a more sustainable funding model.
2.29 Managing a payments system consists of both day-to-day
operations and broader strategic investment and strategy-setting, in
the interests of market innovation, competition, and to ensure
adequate consumer protection. While Pay.UK has delivered from an
operational perspective, it was originally established with the aim of
delivering across a wide set of objectives. However, as noted by
Pay.UK itself, its design – and in particular its current governance
model – has in practice made it very difficult to progress a strategic
agenda as originally envisaged. Under its current model, it is able to
progress activities such as funding new infrastructure or
enhancement projects only with the consent of its members or
through the imposition of regulatory obligations.
2.30 Appropriate governance and funding models are needed to ensure
the UK’s infrastructure needs are delivered now and through time,
and that commercial arrangements are effective and deliver value-
for-money for market users.
Implementing the government’s vision for payments infrastructure
2.31 In light of the above, it is clear to the government that the sector
would benefit from much greater clarity, direction and strategy
regarding the UK’s retail payments infrastructure. Therefore, the
newly established Payments Vision Delivery Committee will task

24
the Bank and the PSR to examine and refresh the requirements
for the UK’s retail infrastructure. This work will:
• Provide greater clarity on the upgrades required to the
UK’s Faster Payments System;
• Assess future requirements for the UK’s retail payments
infrastructure, looking beyond the upgrading of Faster
Payments to consider the needs and development of the
UK’s retail payments at large; and
• Determine the governance arrangements needed to
deliver this, including proposals to reform Pay.UK, drawing
on international comparisons appropriately.
2.32 In leading this work, the Bank and PSR should engage stakeholders
and set out an approach no later than end Q2 2025. In particular,
the government has also asked the Bank and PSR consider the
broader context of regulatory congestion. As highlighted in the
Garner Review, this includes requirements for duplicate
investment across competing infrastructure initiatives, and
impacts on sector capacity. This will be an essential guiding
principle for the Payments Vision Delivery Committee.
2.33 More widely, the government requests that the PSR and Bank of
England consider the aims and objectives set out in this National
Payments Vision and, in particular:
• the need for the UK’s infrastructure to serve equitably a
diverse array of market actors, both in terms of functionality
and access. This reflects the government’s clear commitment to
Open Banking, and the need to support wider market innovation
and competition;
• the importance of innovation to support better outcomes for all
market users, and greater competition and choice in the
making of payments;
• ensuring the safety of the UK’s payments system, and the
importance of system resilience.
2.34 The government will monitor this work through HM Treasury’s
chairing of the Committee. The government also encourages
stakeholders to engage constructively to ensure swift action to
secure the payments ecosystem of today and enable developments
for the ecosystem of tomorrow.
Wider innovation in payments
2.35 In addition to addressing the issues in the existing retail payments
infrastructure relating to commercial bank money, the government

25
continues to make a forward-looking assessment of the role of
public money in a dynamic and fast-moving payments landscape.
2.36 To that end, we will continue the design phase for a retail Central
Bank Digital Currency – known as the Digital Pound – in partnership
with the Bank of England. No decision has been taken on whether
to implement a digital pound, but the UK cannot risk falling behind,
hence we are continuing rapid and careful exploration of all relevant
emerging technologies. More detail on this is outlined in section
three of this document.
2.37 Ensuring the resilience and safety of the systems underpinning UK
payments is of paramount importance. In the context of an evolving
payments ecosystem, the government will continue to consider
whether the Bank of England’s regulatory perimeter remains
adequate for addressing risks to economic and financial stability.

26
Chapter 3
Building for tomorrow –
driving innovation,
facilitating competition and
ensuring security
3.1 The government has taken action to strengthen the regulatory
framework and steer future infrastructure renewal – the key
foundations that create the conditions for the technological
innovations and opportunities of tomorrow. Looking ahead, the
government considers that three key pillars – innovation,
competition and security – should guide industry and regulatory
activity towards delivery of the government’s vision.
3.2 There is substantial activity underway across the landscape today
which aligns with these pillars, and the government does not wish
to add to the congestion currently experienced across the sector
through further initiatives. Instead, the government’s vision should
help to steer existing activities, particularly those which are
considered priorities for delivering the overall ambition of
diversifying today’s ecosystem, harnessing next-generation
technology and maintaining trust in payments.
3.3 It is important that consumers and businesses have choice in how
they transact based on their individual needs and preferences. For
most people, transacting digitally brings significant benefits around
speed, convenience and security. However, the government
recognises that there is a proportion of the population who either
cannot or do not want to use digital payments. Ensuring that
everyone has access to appropriate payment methods is vital to
financial resilience, wellbeing and participation in the economy, so
that no one is left behind in an increasingly digital society.
3.4 The government also acknowledges that further action is required
to address the barriers for those that want to transact digitally but
struggle to do so. It therefore welcomes the Garner Review finding
on the increased risk of financial exclusion through digital exclusion
and agrees with the recommendation to continually monitor this,
including through the FCA’s Financial Lives Survey.
3.5 The following section addresses key existing initiatives which drive
innovation and facilitate competition in payments, including

27
progressing Open Banking. It also considers activity to ensure the
security of the ecosystem into the future, especially tackling
payments fraud. These reflect a number of the themes highlighted
by the Garner Review, and provide a response to the Review’s more
detailed recommendations.
Driving innovation and facilitating competition
Delivering seamless account-to-account payments through Open
Banking
3.6 Individuals and businesses should have choice in how they make and
receive payments, with competition in payment methods leading to
innovation in products and services – from both established players
and new entrants.
3.7 The UK is a heavily card-based market with 29.1 billion payments
made using credit or debit card in 20237. Combined with the rising
use of digital wallets and smart phones, the consumer experience –
particularly for in person contactless payments – is very positive. This
was recognised by the Garner Review. The card schemes also offer
valuable services, such as analytical tools to help merchants identify
consumer spending patterns. Cards play – and will continue to play –
an important role in the UK’s payments ecosystem.
3.8 But there is significant opportunity to further develop account-to-
account payments in the UK – enabling consumers to pay digitally for
goods and services in shops and online, without using a card. This
would provide greater choice to consumers and merchants in how
they make and receive payments, which in turn is likely to spur
innovation and downward competitive pressure on the cost of
payments. The government is already backing and reaping the
benefits of these innovative payments8 and consumers and
merchants should be able to do the same.
3.9 It is the government’s ambition, therefore, that seamless account-
to-account payments are developed as a ubiquitous payment
method. For account-to-account payments to take-off, the
underlying payments infrastructure needs improved functionality.
As set out in Section 2 it is therefore important that the UK’s
payments infrastructure is upgraded in the short term to better
7
See UK Finance’s Payments Markets Summary (pp. 9-10):
8
For example, HMRC receives more Open Banking payments than any other UK
organisation and any other government department in the world, and has now taken
over 10 million payments worth almost £33 billion through Open Banking.

28
support innovation and competition. The user experience is also
essential.
3.10 Open Banking, with its significant untapped potential, has a vital
role to play in achieving this ambition in the near-term – in
particular, through unlocking account-to-account payments for e-
commerce. The government expects the regulators to ensure a
strong focus on competition and choice in their work to support the
development of Open Banking.
The government’s ambition for Open Banking enabled payments
3.11 Through the combination of the Payment Services Regulations9 and
the 2017 Competition and Markets Authority (CMA) order on Open
Banking,10 the UK has led the way in making customer data available
for use by authorised third party providers, through a standard set of
Application Programming Interface (API) standards. This approach
has been hugely successful in safely opening up access to payment
accounts – enabling fintechs to enter the market and provide
innovative products and services. However, there is significant
opportunity for Open Banking to grow beyond the scope of the CMA
Order, following the successful implementation of its roadmap.
3.12 For Open Banking to scale and help deliver more competition and
innovation in the market, it needs to transition to a sustainable long-
term regulatory framework. The government is committed to
delivering this framework and intends to use incoming smart data
powers in the Data (Use and Access) Bill, currently progressing
through Parliament, to do so.
3.13 Ahead of that framework being delivered, the FCA and the PSR have
been working via the Joint Regulatory Oversight Committee (JROC)
and with industry to develop Open Banking beyond the scope of the
CMA Order. The government appreciates the considerable support
that the Open Banking ecosystem has provided to JROC in order to
advance this. However, this work has been slow to progress, which is
partly due to uncertainty around the future regulatory direction for
Open Banking.
3.14 A key strand of this work is developing a ‘phase 1 pilot’ for Variable
Recurring Payments, an innovative type of Open Banking enabled
payment. This pilot is focused on a limited number of lower-risk use
cases such as paying bills. Open Banking is likely to provide benefits
for these use cases – for example by giving consumers greater
9
The Payment Services Regulations 2017 and the FCA’s Regulatory Technical Standards
on Strong Customer Authentication and Common and Secure Methods of
Communication (made under regulation 106(A)).
10
The Retail Banking Market Investigation Order 2017.

29
visibility, flexibility and control of the amounts and timings of their
payments than alternatives such as Direct Debit and the government
therefore supports the conclusion of this work. However, there is even
greater opportunity for Open Banking payments beyond these use
cases, in enabling account-to-account transactions more broadly.
3.15 While there is certainly potential for Open Banking enabled
payments to become ubiquitous, including for physical point-of-sale
transactions, this brings particular technological challenges (for
example around developing the software and hardware required to
facilitate in-person transactions). These challenges are less relevant in
the case of online transactions.
3.16 Recognising the lower barriers to delivery, as well as industry appetite
in this area, the government considers unlocking Open Banking
enabled account-to-account payments for e-commerce to be a
strategic short to medium term priority.
3.17 More broadly, and beyond its role in delivering seamless account-to-
account payments, Open Banking presents significant opportunities
by further enabling customers and businesses to leverage their data
to access personalised, tailored services and finance.
3.18 The government's ambition is for the UK to be a world leader in Open
Finance – the next generation of financial data sharing. The benefits
are potentially transformative for businesses and customers,
enabling choice, innovation and a greater ability to engage with
financial services.
Developing a clearer set of regulatory responsibilities
3.19 For Open Banking to further flourish and successfully deliver
seamless account-to-account payments, the roles of the regulators
need to be clear.
3.20 Through JROC, the FCA and PSR have been working to progress
Open Banking, in dialogue with HMT and the CMA. While some of this
work is now nearing its final stages, progress has been slow and firms
report that engaging with JROC has been challenging. The
government is cognisant that both industry and the regulators have
invested substantial resource in this work, much of which is laying
important foundations for the long-term regulatory framework,
including better mapping API performance, developing tools to
combat financial crime, progressing proposals for a dispute
resolution mechanism and improving information flows. The

30
government therefore supports the swift conclusion of the JROC
Open Banking Roadmap.11
3.21 However, as we look ahead to the future framework being delivered,
the regulators’ roles need to be clarified in order to effectively and
efficiently oversee, and enable the growth of, Open Banking.
3.22 The government considers that Open Banking should develop as an
overlay service for the accessing of account data and initiation of
account-to-account payments. While Open Banking is not a
designated payment system itself, Open Banking initiated account-
to-account payments often rely on payment rails within designated
payments systems overseen by the PSR – chiefly, the Faster Payment
System. Given this close interaction, and the accelerating growth and
sophistication of Open Banking services, it is important to clarify the
regulators’ roles under the future framework.
3.23 Going forward, the government has asked the FCA to be the UK’s
regulator for Open Banking, as envisaged by the Data (Use and
Access) Bill. The government expects the FCA to engage as
appropriate with the PSR, including in relation to the interaction of
Open Banking overlay services with underlying payment rails which
are designated as PSR regulated payment systems, noting the PSR’s
expertise as an economic regulator with innovation and competition
objectives in relation to such systems.12
3.24 The long-term regulatory framework for Open Banking will build on
existing payment account access requirements to create a regulated
scheme for Open Banking. This will include making provision for a
new central body to take on and expand upon the important role that
has been performed by Open Banking Limited. The government
intends for the FCA, with its statutory objectives to promote
competition in the interests of consumers, to be the sole regulator of
this body and the Open Banking smart data scheme.
3.25 Having a single authority leading the regulation of Open Banking
overall will help ensure coherence between the approach to Open
Banking payment initiation and data sharing. The FCA will also be
well placed to consider potential interoperability between Open
Banking and other smart data schemes, given the government’s
intention for this Open Banking framework to lay the foundations for
Open Finance.
11 See JROC’s April 2023 Publication: Recommendations for the next phase of open
banking in the UK (publishing.service.gov.uk)
12 Payment Systems Regulator: designation orders - GOV.UK

31
3.26 When established, JROC was intended to act as a temporary
arrangement to bridge the gap ahead of the permanent framework
being delivered. As such, JROC will be wound down at the earliest
opportunity.
Facilitating innovation and investment through a sustainable
commercial model
3.27 Establishing a sustainable ‘commercial model’ for Open Banking is
critical for its development. The government agrees with the Garner
Review’s assessment that Open Banking’s current economics create
a lack of incentives for data holders to drive, invest and support the
development of Open Banking beyond the regulatory minimum
established in the CMA Order.
3.28 To unleash the potential of Open Banking, sustainable commercial
arrangements are needed. The provision of any additional or
‘premium’ services beyond the scope of the CMA Order should be
subject to a commercial model whereby data holders are incentivised
to innovate and invest. The government intends to support this
through the incoming regulatory framework.
3.29 Under the auspices of JROC, the PSR has led work over the course of
this year, seeking to develop a commercial model for the phase 1 use
cases for Variable Recurring Payments. The government supports an
industry-led approach to the development of this model and expects
it to be delivered quickly and in a way that supports effective
competition.
3.30 While these pilot use cases are important, there is clear benefit too in
driving progress in unlocking Open Banking payments for e-
commerce.
3.31 Although it may build on components of the pilot, the commercial
model for e-commerce use cases will need to reflect different risks
and requirements. Given it will take some time to develop, the
government therefore asks the FCA to commence work to determine
the commercial model for e-commerce uses cases swiftly, and in
parallel to the delivery of the pilot.
3.32 Following the delivery of the VRP phase 1 pilot, the government
expects the FCA to reflect on the lessons learned, including the
progress of industry-led developments. The government expects the
FCA to work closely with the PSR, drawing on its expertise as an
economic regulator, as the FCA takes forward work on the overall
framework for commercial Open Banking payments, including
Variable Recurring Payments. The government expects the FCA and
the PSR to ensure a fully effective handover of the commercial model
once phase 1 is delivered. More generally, the government would like

32
to see all industry partners play their role in supporting the effective
and timely delivery of a sustainable commercial model.
3.33 The government is also aware of concerns about the potential for
significant increases in the use of APIs which are currently provided
for free under the CMA Order, with questions posed in relation to the
fairness of free access at significant scale. In January 2024, the FCA
issued a Call for Input considering the potential competition impacts
from the data asymmetry between Big Tech companies and financial
services firms. The FCA responded to this Call for Input in April, with a
commitment – among other next steps – to conduct further analysis
and keep this under review. The government will consider whether
policy changes are required to align incentives between data users
and holders and support a sustainable funding model for API
development – for example considering reciprocal obligations or
reasonable compensation where certain APIs are accessed at
significant scale.
3.34 The government recognises that the regulatory-led free access
model has been and remains pivotal to democratising access to data,
as well as supporting innovation and competition. The government
is aware that many smaller fintechs rely on free access to APIs and
associated services, to start and grow their business. As such, it is
committed to protecting existing fintech business models. The
government plans to engage further with the ecosystem on these
issues as it develops proposals for the long-term regulatory
framework for Open Banking, including a smart data scheme.
Open Banking consumer protections
3.35 It is critical that payments are safe and consumers are adequately
protected. This includes appropriate recourse when something goes
wrong. Not all types of payment require the same degree of
protection – for example, an ability to swiftly obtain a refund, and
clarity on how to go about this, is more important when buying an
airplane ticket than buying a newspaper.
3.36 Currently, card payments offer greater consumer protection than
payments via bank transfer. The Garner Review recommended
‘addressing the consumer protection gap’ for Open Banking – for
example by establishing a basic level of consumer protection and
clarity on liability for payments made via Open Banking.
3.37 Adequate consumer protection must be delivered for Open Banking
payments, and the government intends to address this through the
future framework. Ahead of that framework being delivered, the
government welcomes work – led by Open Banking Limited and
overseen by the FCA and PSR – to stand up a dispute resolution
process.

33
Enabling the use of safe and trustworthy digital identity products
3.38 In its conclusion on improving person-to-person payments in the UK,
the Garner Review highlighted that countries which have moved
rapidly in this area, notably India and the Netherlands, have done so
by building real time payment systems using national identifiers or
digital identity products.
3.39 Introducing digital identifiers can help ensure that person-to-person
payments remain a competitive and reliable option for consumers.
Currently, the UK consumer needs to input the sort code and account
number to make a payment which can be cumbersome and lead to
errors in sending payments to the correct payee.
3.40 However, there are many sectors that would benefit from a digital
identity initiative and government therefore agrees with Garner’s
suggestion to take a cross-government approach to explore
developments in this area. The Data (Use and Access) Bill, led by the
Department for Science, Innovation and Technology and which is
currently progressing through Parliament, includes measures to
establish a statutory footing for digital verification services without
creating a mandatory digital ID system.
3.41 This legislation is intended to deliver a framework of standards and
governance for providers to offer trusted digital identity services to
those who wish to use them. Through consultation, public dialogue
and engagement with industry, government has developed a set of
standards for reliable and secure digital identity services, known as
the UK digital identity and attributes trust framework.
3.42 Digital verification service providers can be independently assessed
against these standards and over 45 providers have already been
certified
13
. Certified providers that follow government rules are
already delivering hundreds of thousands of digital right-to-work,
right-to-rent and Disclosure and Barring Service checks every
month. This can also be utilised by payment service providers to
allow safe and efficient ways of making payments without needing
sort code and account numbers.
3.43 Financial services is a priority sector for adoption of digital identities
and government continues to engage closely with stakeholders on
opportunities in this space. The government welcomes the work of
the Centre for Finance Innovation and Technology (CFIT) and its
coalition partners to explore the potential of digital verification
solutions to combat economic crime, and will consider any findings
that emerge from CFIT’s work in due course.
13 GOV.UK - List of certified digital identity and attribute services

34
Exploring a potential ‘digital pound’
3.44 The government remains committed to protecting access to cash,
recognising its importance in allowing millions of people (often in
vulnerable groups) to pay for essential goods and services. But with
the emergence of new forms of digital money and new payment and
settlement technologies, the government believes it is also right for
the UK, alongside many other countries, to continue to explore the
concept of a retail Central Bank Digital Currency. The UK’s proposed
retail Central Bank Digital Currency – known as the digital pound –
would be a form of digital banknote issued directly by the Bank of
England. This would be a potential complement to cash and other
payment mechanisms for use by households and business for their
everyday payments needs in the next generation of payments
technology.
3.45 To that end this government will continue the design phase for the
digital pound, in partnership with the Bank of England. A digital
pound could help ensure that money issued by the Bank of England
remains available and useful in an ever more digital economy. It could
also provide, consistent with the government’s pillars for guiding
future activity, a public platform for private sector innovation,
promoting further choice and efficiency in payments. Together with
the Bank of England, the government will ensure the design of a
digital pound maintains financial stability, users’ privacy, and
supports financial inclusion.
3.46 No decision has been taken on whether to go ahead with
implementing a digital pound. This work will be critical in providing
the necessary evidence base to make such a decision in the coming
years. Any decision will also depend on wider trends in money and
payments. Irrespective of the final decision, by partnering with the
private sector on proofs of concept and experiments, the work will
support private innovation in digital currency technologies. It will also
deepen the retail payments expertise of the UK public authorities,
and support the UK in its ambition to further build its global
leadership on payments and fintech innovation.
3.47 Recognising that the introduction of a digital pound would be a
major step, the government also confirms that any decision to
proceed with a digital pound would be accompanied by the
introduction of primary legislation, ensuring full Parliamentary
scrutiny by both Houses of Parliament, before any launch of the
digital pound. Legislation would be preceded by a further public
consultation and would guarantee users’ privacy and control of their
money.

35
Ensuring the security of the UK’s payments ecosystem
Protecting against fraud
3.48 This government is committed to high standards of consumer
protection and ensuring people and businesses can make payments
efficiently and safely. In recent times, a substantial threat to this has
been the rise of fraud. Fraud causes huge economic damage through
losses and through the undermining of trust in key commercial
enterprises including our payment’s ecosystem. The cost of fraud is
also significant, with independent estimates suggesting that fraud
cost UK consumers £8.3 billion last year alone.
3.49 This Vision is intended to respond to the chief issues raised during the
Garner Review, where fraud was the most commonly mentioned
topic. Amongst the Review’s findings was a recommendation that
government should set a more ambitious fraud reduction target. The
government is committed to working with law enforcement and
industry to better protect the public and businesses from this
appalling crime, and will work closely with all sectors to deliver its
manifesto commitment of a new fraud strategy.
3.50 While this Vision primarily sets out the government’s response to the
issues raised in the Garner Review on fraud, it is important to
emphasise that identifying and stopping fraud is only the first
opportunity for firms to prevent the onward transfer of criminal funds,
for use in wider organised crime and to cause further damage to
society. Payment firms should therefore also remain focused on
meeting their obligations to tackle economic crime more broadly,
including money laundering, terrorist financing and sanctions
evasion.
Ensuring clear and proportionate regulation
3.51 The Garner Review highlighted that a National Payments Vision could
clarify the responsibilities of different authorities in tackling fraud. The
government considers that fraud policy represents a clear example of
regulatory overlap in the responsibilities of the Payment Systems
Regulator and the FCA. As referenced in the accompanying remit
letter, the government welcomes commitments from the FCA, as the
responsible regulator for the conduct of payment service providers,
to lead work to manage existing overlaps between the FCA and PSR’s
exercise of their functions on fraud.
3.52 Innovation is key to ensuring firms can tackle the evolving threats
posed by fraudsters. The government therefore believes it is
important that regulation can support firms to adopt new solutions
that protect consumers from this appalling crime. The Garner Review
recognised this and found that the implementation of Strong
Customer Authentication (SCA) requirements5
had succeeded in

36
reducing fraud rates but has resulted in burdensome frictions which
impact the customer’s experience, including a lack of flexibility
around contactless limits. The Review recommended that the
government should seek to remove the prescriptive requirements in
the relevant technical standards and instead place them in regulatory
rules and/or guidance.
3.53 The government agrees with this recommendation and is committed
to commencing the revocation of the payments authentication
regulations relating to SCA in the Payment Services Regulations 2017.
This will enable the FCA to incorporate aspects of the technical
standards into its rules, allowing for more agile and outcomes-based
rulemaking, in turn providing industry more flexibility to effectively
prevent fraud while improving the customer payments experience.
Focusing on upstream prevention, including intelligence sharing
3.54 The UK has put in place strong consumer protections for fraud,
including through reimbursement of authorised push payment fraud
as mandated by the Payment Systems Regulator. While this regime
provides a critical safety net for consumers, it introduces new risks for
firms to manage. In line with the recommendation made in the
Garner review, the Payment Systems Regulator has confirmed it will
commission an independent post implementation review of its policy
after 12 months of the policy being in force.
3.55 However, the government agrees with the Garner review that more
focus must be placed on fraud prevention. Reducing levels of fraud
will support competitiveness and growth by ensuring consumers and
businesses have trust in our financial services sector.
3.56 In this vein, the government has already acted quickly to give
payment service providers powers to delay the processing of select
payments broadly when there are reasonable grounds to suspect
authorised push payment fraud, and more time is needed to engage
the customer or a relevant third party, such as law enforcement.
While the government is clear that this tool must be used
proportionately and not as a means to systematically disrupt
legitimate payments or de-risk entire sectors, it will support firms in
their efforts to combat the most complex cases of authorised push
payment fraud and “break the spell” of fraudsters. We have also seen
the financial services sector engage in valuable public-private
partnerships to combat fraud and wider economic crime upstream.
For example, the Joint Money Laundering Intelligence Taskforce
facilitates the sharing of information between law enforcement
agencies and the private sector to detect and prevent economic
crime threats, including fraud.
3.57 While these are positive steps, it is clear that more can be done to
prevent fraud upstream, including through sharing intelligence, both

37
within and across sectors. Within the financial services sector
specifically, there are a number of promising solutions which allow
firms to share data for the purposes of tackling fraud, either before a
transaction is initiated or real-time during the processing of a
payment. With its renewed focus on upstream fraud prevention, the
government would like to see the adoption of intelligence sharing
initiatives prioritised moving forward.
3.58 In the payments remit letter published today, the government
therefore welcomes the forthcoming work by the financial services
regulators to work in partnership with the financial services sector to
better understand the different intelligence sharing solutions
available and the barriers to their wider adoption.
Adopting a cross sectoral approach to tackling fraud
3.59 Authorised push payment fraud ends with the sending or receiving
of a payment, but that is not where it starts. Evidence collected
consistently shows that fraudsters are exploiting online platforms
and telecommunications networks to access and coerce victims. The
government is clear that all actors across the chain, including from
these sectors, must play their full part in stopping fraud upstream.
3.60 The government welcomes the voluntary steps that have been taken
to date by these sectors, and notes that important statutory changes
will soon also be implemented. Notably, the Online Safety Act 2023
imposes obligations on large technology platforms to prevent
fraudulent content on their services or face substantial fines if they
fail to do so. There is also ongoing work from Ofcom with operators
to prevent the misuse of telephone numbers by criminals, stem the
tide of scam messages and address mobile spoofing.
3.61 However, despite progress, overall fraud rates remain too high and
the scale of fraud originating on online platforms and
telecommunication networks continues to pose a significant risk to
the wider growth, prosperity, and security of the UK. It is clear that
more needs to be done now to stop these platforms being exploited
by fraudsters. The government is therefore determined that the
technology and telecommunications sectors must take further steps
to tackle fraud.
3.62 The government has therefore today written to the technology and
telecommunications sectors to call for demonstrable action to
reduce the scale of incidents and losses from fraud taking place on
their platforms and networks. The government will request updates
on progress and action taken at the next Joint Fraud Taskforce in
March 2025. The government will continue to monitor the issue.

38
Chapter 4
Implementing the National
Payments Vision
4.1 The National Payments Vision aims to spur innovation and
investment, and secure the UK’s position as a world leader in
payments. Achieving this Vision will require collaboration across the
ecosystem, including between public authorities, financial services
providers and end-users. The shared commitment to deliver growth
of this sector is clear, with strong engagement from key
stakeholders across the banking and fintech sectors, consumer
representatives, merchants and regulators over the course of this
work.
4.2 Beyond a vision, the Garner Review called for strategic prioritisation
decisions across existing regulatory initiatives to help alleviate the
regulatory burden. The UK’s model of financial regulation,
established by the Financial Services and Markets Act 2000,
delegates significant responsibility to expert, operationally-
independent regulators, working within an overall policy framework
set by government and Parliament. Therefore, decisions relating to
initiatives led by the regulators must be taken by them, but within
the context of government’s priorities as set out in the National
Payments Vision and having regard to the recommendations in the
Payments remit letter.
The Payments Vision Delivery Committee
4.3 The government is establishing the Payments Vision Delivery
Committee, comprised of senior representatives of the Bank of
England, FCA and PSR, with responsibility for ensuring coordination
between the regulators. It will provide a mechanism to facilitate
prioritisation decisions on initiatives. HM Treasury will chair the
Committee to support this work and help ensure decisions are
aligned with the government’s vision.
4.4 The Committee will run for an initial period of 9-12 months, after
which its future role will be assessed. Its key outputs will be to:
• Outline proposals on the UK’s retail payments infrastructure
needs and the governance and funding arrangements
required to deliver this, led by the Bank of England and PSR.
• Publish a sequenced plan of future initiatives (the Payments
Forward Plan), outlining decisions to streamline activity and

39
provide clarity on regulatory requirements in the future
landscape.
4.5 The Committee will be supported by a cross-authority secretariat.
Working in partnership with the sector to deliver the Vision
4.6 Direction from government and a clear regulatory approach is vital
in providing the guardrails to guide the ecosystem, but growth must
be delivered through collaboration with industry partners – spurring
innovation and grasping the opportunities of next generation
technology.
4.7 The Garner Review called on government to consider ‘a more
supportive and collaborative relationship between regulators and
industry’ to improve future outcomes. Enhanced collaboration
between government, regulators and industry is critical to delivering
the government’s growth mission and renewed partnership with
the private sector is required to deliver the government’s ambitions
for UK payments.
4.8 The stakeholder landscape for payments is broad, with varied and
often conflicting views. In taking decisions on the UK’s future retail
payments infrastructure needs and sequencing of regulatory
initiatives, there must be clear channels for the Payments Vision
Delivery Committee to consider representations across the
ecosystem.
4.9 Therefore, the Payments Vision Delivery Committee will be
supported by the Vision Engagement Group. The group will
comprise public and private membership – senior officials of the
regulators and HM Treasury will be standing members, and rotating
members will include representatives across the sector, ensuring a
collaborative approach to progressing work for the Committee’s
decision.
4.10 Private sector participation in the Vision Engagement Group will be
subject to an open application process. This participation will reflect
the breadth of the UK’s payments stakeholder landscape – including
financial services providers, fintechs, merchants and consumer
representatives.
4.11 Further detail on the Payments Vision Delivery Committee can be
found in the accompanying Terms of Reference.

40
HM Treasury contacts
This document can be downloaded from www.gov.uk
If you require this information in an alternative format or have general
enquiries about HM Treasury and its work, contact:
Correspondence Team
HM Treasury
1 Horse Guards Road
London
SW1A 2HQ
Tel: 020 7270 5000
Email: public.enquiries@hmtreasury.gov.uk

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