Access to industry-leading payment solutions in a safe, reliable environment is essential for the UK to prosper in the competitive global market. At present, the United Kingdom possesses a robust payments infrastructure characterised by extensive digital adoption, industry-leading capabilities, and a meticulously regulated setting. The nation illustrates exceptional proficiency in both in person and digital payment transactions, where contactless payment methods and digital wallets significantly augment the consumer experience. However, the United Kingdom must continue to innovate and adapt to prevail at the forefront of the payments landscape.
As part of the 2023 Autumn Statement, “The Future of Payments Review,” which was commissioned by HM Treasury and presided over by Joe Garner, is published. It presents a multitude of recommendations concerning the United Kingdom’s progression towards establishing a retail payments environment of the highest calibre.
The Review aims to identify the most important consumer retail payment journeys today and in the next 5 years, assess the UK’s consumer experience compared to other leading countries for quality, security, and cost, and evaluate the possibility of in-flight plans and initiatives delivering world-leading payment journeys for UK consumers.
Future of Payments Review: Highlights
The review suggests that despite the UK’s strong position in the payments landscape, there is a lack of vision and clarity of priorities, rendering it difficult to have high confidence in achieving a coherent outcome in the next 5-10 years. The absence of a clear agreed vision for in-flight plans and initiatives across the payments landscape is a concerning issue.
To address these challenges and propel the UK towards a world-leading payments environment, the Future of Payments Review strongly recommends the development of a national payments vision and strategy. This recommendation is underpinned by several factors:
- Criticality of Payments
Recognising the critical role of payments to consumers and the economy, emphasising that a world-class payments ecosystem is essential for the economy as well as the lives of every member of the society.
- Billions of Pounds in Investment
Considering the substantial investments being made in the payments sphere.
- Interdependent Nature of the Payments Arena
Acknowledging the highly interdependent nature of the payments landscape, wherein the various components of the ecosystem rely on each other for seamless functioning.
National Payments Vision and Strategy for the UK
The development of a National Payments Vision and Strategy is intended to provide a guiding framework for the future of payments. Its primary aim is to simplify the complex payments landscape over time, ensuring that the payments ecosystem is healthy and conducive to fostering small business growth, frictionless trade, and innovation in the FinTech sector.
Moreover, the strategy is expected to address key concerns and areas for improvement identified in the review, including:
- Simplifying the Landscape
Streamlining the payments ecosystem to ensure greater coherence and efficiency.
- Consumer Experience
Enhancing the consumer experience by addressing issues such as the clunky consumer-to-consumer bank transfer process, financial exclusion, and the costs and lack of viable alternatives for merchants and retailers in accepting card payments.
- Open Banking
Capitalising on the potential of Open Banking by addressing consumer protection and commercial arrangement concerns to improve person-to-person bank transfers and provide an alternative to card schemes.
Significance of National Payments Vision and Strategy
This is important because payments are crucial for economic growth and are a major part of the UK’s infrastructure. The Government should provide high-level guidance to align regulators and industry in their delivery. The vision should prioritise safety, simplification, coordination, responsiveness to innovation, inclusivity, and accountability.
The strategy should address ambiguous areas such as resilience vs. customer convenience, competition at the infrastructure level, international vs. domestic payments infrastructure, roles of regulators and industry bodies, fraud and financial crime, interoperability, and digital ID for payments.
Currently, these questions are being worked through by different interest groups, which is slow and inefficient. A National Payments Vision and Strategy would settle on better-aligned initiatives and provide clarity of direction.
Key Concepts Covered in the Future of Payments Review
- The review highlights the need for a National Payments Vision and Strategy in the UK. One key aspect emphasized in the review is the importance of consumer experience within the payments landscape. The strategy aims to address the balance between resilience, safety, and customer convenience, ensuring that the evolving payment systems prioritize a seamless and user-friendly experience for consumers.By focusing on the consumer experience, the strategy seeks to enhance trust, accessibility, and efficiency in all aspects of payments, ultimately aiming to improve satisfaction and confidence in the payment ecosystem.
- The proposed National Payments Vision and Strategy also aligns with the principles of Open Banking. It recognises the significance of competition and innovation in driving progress within the payments sector. The strategy seeks to promote greater competition at both the infrastructure and consumer experience levels, fostering an environment where new entrants can contribute to a more dynamic and responsive payments landscape. By embracing Open Banking principles, the strategy aims to facilitate the development of innovative payment solutions, ultimately benefiting consumers, businesses, and the wider economy.
Regulatory Oversight and Alignment
- In the context of regulatory oversight and alignment, the review underlines the necessity for a coherent national strategy to provide clear direction for regulators and industry bodies. The proposed strategy acknowledges the role of regulators in ensuring safety, security, and fair competition within the payments ecosystem. It aims to establish guiding principles that promote coordination between regulators and industry players, fostering an environment of accountability, transparency, and responsiveness to innovation.
Crucial Conclusions for Improved Payment Landscape in UK
The Future of Payments Review features ten primary conclusions and recommendations stemming from extensive consultation and research. These conclusions center on various aspects of the payments landscape, including consumer spending, open banking, regulatory oversight, and global insights. Here are detailed notes on the ten conclusions mentioned in the review:
Conclusion 1: Consumer spending in person
- This conclusion addresses on capitalising on the opportunities presented by the Smarter Regulatory Framework and the post-Brexit era, HM Treasury ought to eliminate the technical standards based on PSD that impede the customer experience, particularly those pertaining to Secure Customer Authentication. It is advisable to substitute these with outcomes-based guidelines that provide implementation flexibility and enable organisations to innovate in order to meet the regulatory objectives. Additionally, fostering the expansion and magnitude of open banking will aid in the improvement of the in-person purchasing experience.
Conclusion 2: Consumer spending online
- This conclusion focuses on improving the online shopping and payment experience for consumers, potentially involving recommendations for enhanced digital payment security, streamlined e-commerce transactions, and increased consumer confidence in online purchases. Before all else, outcomes-based guidance should take precedence over prescriptive PSD regulations.The Review also urges governments to contemplate the adoption of digital wallets, which are amassing an increasingly substantial portion of global payment volume, in a transparent manner towards international participants
Conclusion 3: Addressing digital and financial exclusion
- This involves strategies to address the challenges of digital and financial exclusion, aiming to ensure that all individuals, regardless of their socioeconomic status or location, have access to and can benefit from modern payment technologies and financial services.Potential options proposed included the incorporation of digital exclusion into the FCA Financial Lives Survey, increased adoption of Request to Pay, and industry innovation challenges that advocate for financially inclusive solutions. Additionally, the United Kingdom can gain insights from other nations that are utilising digital solutions to combat financial exclusion, as opposed to the possibility that digital solutions will exacerbate financial exclusion.
Conclusion 4: Addressing the consumer protection gap
- This proposal concerns endeavours to enhance consumer protection protocols within the domain of payments, with an emphasis on mitigating risks associated with fraudulent activities, unauthorised financial transactions, and data breaches, while simultaneously protecting the rights of consumers in digital financial transactions.In accordance with the Review, HM Treasury, JROC, and participants should prioritise at least rudimentary purchase protections, a dispute resolution system, and liability clarity. Presently, the consumer protection framework is intricate and dispersed, encompassing the APP Fraud regime, Direct Debit guarantees, Payment Services Directive, and Consumer Duty. However, there exists a critical void concerning open banking payments.
Conclusion 5: Improving person-to-person payments
- The focus of this conclusion is on strategies for enhancing payment methods between persons, with a potential spotlight on the importance of real-time, secure, and user-friendly peer-to-peer payment solutions.The industry should consider certain clear success criteria such as widespread reach, commercial sustainability, integration into the customer journey, and the use of an alias, proxy, or national identifier to eliminate the necessity of entering lengthy sort codes and account numbers. On this subject, the government and industry may have the capacity to collaborate more closely with Big Tech providers.
Conclusion 6: Multiple payments options for retailers and merchants
- This highlights the importance of offering diverse payment options for retailers and merchants, potentially involving suggestions for facilitating the acceptance of various payment methods and promoting a competitive and inclusive payments ecosystem.The government must expedite efforts to address the consumer protection, user interface, and commercial model voids that presently impede the adoption of open banking, while the PSR must continue its review of interchange pricing to ensure competition and promote greater merchant choice.
Conclusion 7: Making the commercial arrangements sustainable
- This conclusion signifies fostering sustainable and equitable commercial arrangements within the payments industry, potentially involving recommendations for fair and transparent fee structures, revenue sharing models, and business relationships.
Conclusion 8: Tackling frauds and scams
- This conclusion pertains to strategies for combating payment-related frauds and scams, potentially focusing on enhancing fraud prevention measures, raising awareness about common scams, and fostering collaboration between stakeholders to mitigate security risks.Particular suggestions were presented with the intention of examining and possibly improving the current APP Scam regulations. Following 12 months, a comprehensive cost-benefit analysis of the new rules should focus on any negative effects.
Conclusion 9: Promoting the ecosystem for fintech prospects
- This involves recommendations for creating a conducive environment for fintech innovation and growth within the payments sector, primarily emphasising the streamlining of regulatory processes, clarification on the application of certain existing regulations to fintechs (like AML checks, APP rules, EMI interest payments and EMI central bank deposits), encouraging collaboration between traditional financial institutions and fintechs, and promoting fintech-friendly policies.
Conclusion 10: Aligning and prioritising regulatory and industry initiatives
- This conclusion underscores the importance of aligning regulatory efforts with industry initiatives within the payments landscape, potentially involving recommendations for harmonising regulatory frameworks, fostering collaboration between regulatory bodies and industry stakeholders and prioritising key industry reforms.
These conclusions collectively underline the comprehensive nature of the Future of Payments Review, addressing various facets of the payments ecosystem and offering actionable recommendations to enhance the consumer experience, promote innovation, and ensure the sustainability and security of payment methods.
Macro Global’s Analysis on Future of Payments Review
In our view, by presenting current trends and the future prognosis, the Future of Payments Review provides a comprehensive synopsis of the payments environment in the United Kingdom. Maintaining the United Kingdom’s preeminent status in the payments industry necessitates an emphasis on competition, innovation, data security, consumer protection, and international cooperation. As a catalyst for progress in payments technology and services, the review promotes ongoing experimentation and innovation.
The review supports the notion that a competitive payments market would enable consumers to obtain greater value and variety. Furthermore, it underscores the significance of implementing strong consumer safeguards and data protection protocols. The review encourages industry participants and regulators to collaborate in order to facilitate international transactions that run smoothly.
Nevertheless, a deeper investigation of specific concerns, such as prescriptive regulatory changes and ecosystem-based operational methods, would have been advantageous for the review. A more streamlined approach could have been taken to prioritise industry initiatives, with an emphasis on those that possess the greatest potential for impact. In addition, emerging concepts that are reshaping the payments landscape, such as digital ID, embedded finance, and open banking, may have received more attention in the review.
Further factors to contemplate involve conducting a comparative assessment of the payment environment in the United Kingdom in relation to other prominent economies. This underscores the significance of regulatory agility in order to reflect the swift progression of the payments sector. Additionally, a stronger focus on consumer education and financial inclusion would have been worthwhile for the review, ensuring that every consumer has the ability to utilise and gain from cutting-edge payment solutions.
Although the completion of the Review represents a noteworthy achievement, the Government is confronted with substantial choices to resolve and an extensive workload to compile a practical strategy for execution. At this time, there is no official regulatory pressure on businesses to proactively implement these recommendations; therefore, it will be the responsibility of the government, regulators, and industry to collaborate in order to stimulate progress.
Macro Global stands ready to empower firms to embrace this transformative journey, shaping a future where payments are secure, seamless, and inclusive, driving economic prosperity and societal well-being.
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