Global payment matters - January 2026
Upcoming developments for the payment sector
09 février 2026
Global payment matters - January 2026Upcoming developments for the payment sector09 février 2026 We’re delighted to share our Knowledge team’s insights on the most important legal changes affecting the payment sector around the globe. This bulletin reflects the current position as of 5 January 2026 and may be subject to change. Payment sector on the horizon: What do I need to know?Global1. Financial Stability Board urges action to improve cross-border payments On October 9, 2025, the Financial Stability Board (FSB) published a progress report on the G20 Roadmap for cross-border payments.
Impact: The FSB has called for stronger implementation at national levels and greater private-sector engagement. Over the coming year, its focus will shift from policy design to supporting implementation and stakeholder coordination, with jurisdictions expected to embed agreed measures into domestic payment frameworks. Asia2. Hong Kong: Project Ensemble pilot (“EnsembleTX”) to advance real-time settlement for tokenized deposits and digital assets On November 13, 2025, the Hong Kong Monetary Authority launched “EnsembleTX”, the pilot phase of Project Ensemble, to enable real-value transactions using tokenised deposits and digital assets. Building on earlier sandbox experimentation, the pilot will operate through 2026 with the aim of delivering faster, more transparent and efficient settlement of real-value tokenised transactions. The HKD Real Time Gross Settlement (RTGS) system will initially facilitate interbank settlement, before the pilot infrastructure is gradually updated to support 24/7 settlement of tokenized Central Bank Money (CeBM). Impact: Banks and industry participants involved in the pilot should prepare to integrate tokenised deposit use cases into liquidity and treasury operations, and test settlement procedures. They should also assess system readiness for the interoperability layer, and reinforce corresponding risk and control frameworks. Other industry participants should monitor developments in tokenisation infrastructure and consider potential operational, risk and compliance implications as broader tokenised asset transactions evolve. 3. Singapore: MAS launches BLOOM to extend settlement capabilities On October 16, 2025, the Monetary Authority of Singapore launched BLOOM (Borderless, Liquid, Open, Online, Multi‑currency) to extend settlement in tokenised bank liabilities and well‑regulated stablecoins, while applying standardised risk approaches. Under BLOOM, industry participants will collaborate on focus areas including the distribution and clearing of settlement assets, programmable compliance controls to automate compliance checks, and agentic payment. Impact: Industry participants such as banks, financial institutions, and clearing and settlement network operators may apply to take part in trials conducted under BLOOM and advance BLOOM’s objectives. They should also keep abreast of further related developments. Europe4. EU: Council backs legal framework for a digital euro and strengthens the role of cash On December 19, 2025, the Council of the EU agreed its position on two regulations: one establishing a legal framework for a retail digital euro to complement cash, and another reinforcing cash as legal tender. The Council clarified key design features, including distribution via supervised intermediaries, holding limits, offline functionality, and Member State duties to monitor cash acceptance and availability. Impact: Banks and PSPs should assess wallet onboarding, privacy and AML/CFT controls, holding-limit monitoring and offline use. Merchants should review digital-euro acceptance flows, point-of-sale integration, and enhanced cash-acceptance and fallback expectations. 5. EU: Verification of Payee (VoP) rulebook updates and consultations On December 18, 2025, the European Payments Council launched two key publications linked to the Verification Of Payee (VOP) scheme rulebook and related documents. It also opened consultations to stabilise version 1.1 and gather change requests for version 2.0 in 2026. The updates support IBAN–name checks for SEPA Credit Transfers (SCT) and SEPA Instant Credit Transfers (SCT Inst). Impact: EU PSPs should finalize IBAN–name check designs, including mismatch outcomes, customer journeys and exception handling. PSPs should also plan for self-certification and testing using EPC tools ahead of early-2026 documentation updates. 6. EU: AMLA moves toward direct supervision of high‑risk institutions On December 18, 2025, the Anti‑Money Laundering Authority (AMLA) advanced preparations to directly supervise around 40 high‑risk financial institutions from 2028, including consultation on cooperation and transfer of supervisory powers. Impact: Groups potentially in scope should refresh enterprise‑wide AML/CFT risk assessments, inventory models and data flows, and strengthen governance documentation and board MI in anticipation of harmonised expectations. 7. EU: Better Data Sharing Regulation published in the Official Journal On October 21, 2025, the Better Data Sharing Regulation has been published in the EU Official Journal, introducing targeted amendments to EU financial legislation to reduce duplicative supervisory reporting. It reinforces the “report-once” principle, clarifies conditions for data sharing between EU authorities, and adjusts certain reporting frequencies. Impact: Financial institutions should expect streamlined supervisory data requests over time, but should review internal data governance, reuse controls and audit trails. Businesses should also monitor future steps towards more integrated EU reporting frameworks. 8. EU: New rules for Euro Payment Safety On October 9, 2025, the European Commission (EC) announced new EU regulations enabling instant euro payments. Citizens and businesses can now transfer money in seconds, 24/7, across the EU. The rules aim to enhance security and reduce costs for instant credit transfers. The EC expects widespread adoption by 2026, with the goal of making instant payments the default option for euro transactions. This initiative is part of the EU's broader strategy to modernize payment systems and promote digital financial services. The regulation is designed to foster innovation and create a stable, competitive environment for the EU's payment services sector. Impact: The new rules allow businesses to receive and send payments instantly. Cash flow management becomes easier and more predictable. Costs for euro transfers may decrease. Businesses can offer faster payment options to clients and suppliers. Operational processes may need minor adjustments to integrate instant payments. Overall, adoption could improve efficiency and competitiveness within the EU market. UK9. Payment Systems Regulator acts on card scheme and processing fees On December 19, 2025, the Payment Systems Regulator set out measures to improve transparency and governance for card scheme and processing fees, following its market review which found limited competition and rising costs. Measures focus on clearer fee information from acquirers and stronger, evidence-based pricing decision-making by schemes and processors. Impact: Acquirers and merchants should prepare for deeper disclosure and re‑examine pricing models and pass‑throughs; issuers and schemes should assemble cost and service evidence for engagement during 2026. 10. FCA updates on commercial VRPs and launches the UK Payments Initiative (UKPI) On December 16, 2025, the FCA published an update on commercial Variable Recurring Payments (cVRPs) and announced the UK Payments Initiative (UKPI), consolidating open banking progress and setting reliability and availability expectations for APIs. Impact: The FCA aims to expand cVRPs into e-commerce and unlock new open banking use cases, driving innovation and competition in payments. In support of this objective, the FCA will engage with industry throughout 2026 and assess progress against key milestones:
11. FCA prioritizes stablecoin payments for 2026 On December 10, 2025, the FCA set out growth measures for 2026 including support for UK‑issued stablecoins to provide faster, more convenient payments, with sandbox testing for safe experimentation. Impact: Banks, EMIs and crypto firms should align issuance/redemption, backing‑asset custody and wallet risk controls with the evolving regime and prepare for sandbox participation. 12. Payments Vision Delivery Committee sets out new payments strategy On November 7, 2025, the Payments Vision Delivery Committee released its strategy for next-generation UK retail payments infrastructure. The Committee includes HM Treasury (HMT), the Bank of England, the Financial Conduct Authority, and the Payment Systems Regulator.
The strategy also supports emerging technologies like programmable payments and stablecoins, alongside improved cross-border payment capabilities. It will be followed by the Payments Forward Plan, which will provide a sequenced roadmap for future payments initiatives. Impact: The plan aims to deliver faster, safer, and more innovative payment options for consumers and businesses. Businesses are encouraged to:
13. The Financial Conduct Authority publishes research note on open banking services On October 6, 2025, the Financial Conduct Authority (FCA) published a research note on the current state of open banking services. The FCA commissioned consultancies KPMG and Europe Economics to collate views on open banking and open finance in the UK. The note:
Impact: The findings summarized in the note do not reflect FCA views or policy positions. Instead, they will contribute to its broader programme of work on open banking and open finance. The FCA will continue to build on this foundation through targeted initiatives and regulatory development. US14. Federal Reserve publishes biennial debit card report (2023 data) On December 19, 2025, the Federal Reserve released its biennial report on debit card transactions, summarising interchange fees, issuer costs and fraud losses across major networks for 2023. Impact: Issuers, acquirers and merchants should update fraud‑loss assumptions and interchange‑sensitive product economics and review divergences by channel and network. 15. FDIC proposes GENIUS Act application rules for payment stablecoin issuers On December 16, 2025, the FDIC issued a Notice of Proposed Rulemaking (NPRM) for an initial set of rules related to implementing the Guiding and Establishing National Innovation for U.S. Stablecoins Act (GENIUS Act). These initial rules would set out the application process that subsidiaries of FDIC‑supervised financial institutions must follow in order to obtain approval to issue payment stablecoins. The rule details filing requirements, statutory evaluation factors, timelines for decisions, and hearing and appeal procedures for denied applications. Public comments are invited for 60 days following publication in the Federal Register. Impact: FDIC‑supervised institutions exploring stablecoin issuance will need to prepare for a formalised, regulator‑driven approval process with detailed application content, governance expectations, redemption‑policy requirements, and if approved, ongoing regulatory supervision. Subsidiaries of these entities seeking designation as permitted payment stablecoin issuers must demonstrate management competence, robust compliance, and adherence to GENIUS Act statutory criteria. 16. State Attorneys General investigate BNPL providers On December 1, 2025, several US State Attorneys General issued information requests to major BNPL providers, seeking data on product design, disclosures, repayment performance and customer outcomes. Impact: BNPL firms may wish to review their affordability checks, disclosures, arrears handling, and complaint trends, as the CFPB is collecting information that could inform future supervisory expectations and potential rulemaking. 17. Fed proposes ‘skinny’ master accounts to spur innovation On October 21, 2025, Federal Reserve (Fed) Governor Christopher J. Waller outlined plans to introduce “skinny master accounts," (also called “payment accounts”) which would offer more limited access to Federal Reserve payment services without full master account privileges, such as interest-bearing balances, overdraft facilities, or discount window borrowing. To manage risk, the Fed would impose balance caps on skinny accounts. The Fed has stated that it does not plan to expand eligibility for the new account type beyond chartered institutions otherwise entitled to apply Impact: Eligible depository institutions, including state banks with limited-purpose or payments-focused charters, should monitor the Federal Reserve’s proposal for limited function master accounts. The Fed’s initiative could inform future discussions around expansion of direct access beyond traditional depositories. Co-authored by Jonathan Botham, Westley Trimble, Paola Paccani and Uendi Barreti Further resources:
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