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News

The Payments Newsletter including Digital Assets & Blockchain, April 2026

22 April 2026
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The Payments Newsletter including Digital Assets & Blockchain, April 2026
Chapter
  • Chapter

  • Chapter 1

    STOP PRESS: UK government announces measures to support adoption of future payments technology
  • Chapter 2

    Regulatory Developments: Payments
  • Chapter 3

    Regulatory Developments: Digital Assets
  • Chapter 4

    Market Developments
  • Chapter 5

    Surveys and Reports

Key developments of interest over the last month include: the European Central Bank publishing a comprehensive Eurosystem Payments Strategy; the Reserve Bank of Australia confirming the decision to remove surcharging, reduce interchange fees and increase fees transparency following the Payments System Board's Review of Merchant Card Payment Costs and Surcharging; the UK FCA publishing a consultation on perimeter guidance for cryptoasset activities; and the U.S. FDIC approving a notice of proposed rulemaking to establish GENIUS Act requirements for permitted payment stablecoin issuers and insured depository institutions.

In this Newsletter:

  • STOP PRESS: UK government announces measures to support adoption of future payments technology
  • Regulatory Developments: Payments
  • Regulatory Developments: Digital Assets
  • Market Developments
  • Surveys and Reports

For previous editions of the Payments Newsletters, please visit our Financial Services practice page.

Chapter 1

STOP PRESS: UK government announces measures to support adoption of future payments technology

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As part of UK Fintech Week 2026, on 21 April the government announced a package of measures aimed at equipping the UK's payments sector for the future of rapid financial innovation.

The package includes: a forthcoming consultation on wider payment services reforms (eg to bring payment services and e-money within the FSMA framework, introduce a regulatory regime for stablecoins used for payments, and explore the regulatory implications of agentic payments); publication of a draft SI amending the Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2026 to exempt stablecoin payments firms from the requirement to obtain authorisations for cryptoasset dealing and arranging under the new cryptoasset regime from October 2027; the appointment of Chris Woolard CBE as the government's new Wholesale Digital Markets Champion; and publication of the government's response to its consultation on bringing the Payment Systems Regulator into the FCA. See this Our Thinking article for further information.

We will cover this development in more detail in the May edition of the Newsletter.

Chapter 2

Regulatory Developments: Payments

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United Kingdom: FCA publishes Work Programme 2026/27

On 26 March 2026, the FCA published its Work Programme for 2026/27. The Work Programme continues to build on the four strategic priorities from the FCA’s five-year Strategy, namely being a smarter regulator, supporting economic growth, helping consumers navigate their financial lives, and fighting financial crime.

Points of interest from the Work Programme include:

  • AI features prominently, with plans to further invest in its AI teams and capabilities as well as:
    • Using generative AI to speed up document review across its authorisation and supervisory work;
    • Integrating AI into regulatory workflows, enabling more effective detection of harm and faster regulatory decision-making; and
    • Progressing use of the Supercharged Sandbox to enable firms to trial AI driven financial innovations in a controlled environment, strengthening the evidence base for future policy and safe market adoption.
  • The FCA also plans to continue building regulatory readiness for quantum computing.
  • It will further adapt its supervisory approach, increasing the number of firms it has touchpoints with, and tailoring its ongoing supervisory approach based on risk.
  • There are plans for a multi-firm project among smaller payment firms to identify good practice and areas for improvement on treatment of vulnerable consumers, as referred to in its Payments Regulatory Priorities Report.
  • The FCA will identify good practice examples of firms harnessing innovation, alongside common themes, risks and opportunities, using insight from its Innovation Hub.
  • A “flagship” financial crime conference will be convened, at which it will showcase how data and technology can improve detection, prevention and disruption.
  • It will explore whether “more proportionate, streamlined approaches” to Know Your Customer (KYC), particularly on smaller transactions, could reduce the burden and cost to firms while maintaining standards.
  • The Work Programme includes information on the FCA’s Budget for 2026/27. Giving a further indication of where its priorities will lie in 2026/27, the top three initiatives in terms of financial resource allocation in the “exceptional projects” section of the new Budget are: Smarter Regulatory Framework (£13.4m); Cryptoasset regime (£9.0m); and Open Banking/Open Finance (£4.6m).
  • The FCA has also published a consultation on its 2026/27 fees and levies, which closes on 30 April 2026. Subject to FCA Board approval in June 2026, it plans to publish a policy statement with final rules in early July.

For further information on the FCA’s latest Work Programme, see this Our Thinking article.


United Kingdom: FCA publishes Perimeter Report 2026/27

On 26 March 2026, the FCA published its latest Perimeter Report setting out both existing and new perimeter issues on which it believes government action is needed. It has also now been confirmed that the King’s Speech 2026, which will set out the government’s legislative agenda for the year ahead, will be delivered on 13 May 2026.

A number of proposed perimeter changes remain on the FCA’s list, including:

  • Senior Managers and Certification Regime (SMCR): The FCA reiterates its view that Recognised Investment Exchanges, Credit Reference Agencies, and Payments and E-money firms should be brought into scope.
  • Cryptoassets: Further legislative development would help ensure a comprehensive, coherent regime.
  • Payments and e-money: As part of the ongoing work to modernise and future-proof the regulatory framework, the FCA is considering new market developments and innovations such as tokenised payments including stablecoin, and agentic payments.
  • Online safety: The FCA would like to see the Online Safety Act (OSA) strengthened by eliminating a loophole which results in User Generated content, such as sponsored adverts by influencers, not being captured by the Fraudulent Advertising duties in the Act.

Issues that are new to this year’s Perimeter Report include:

  • AI – general-purpose LLMs: Consumers are increasingly asking “general-purpose” large language model (LLM) platforms, such as ChatGPT or Claude, for help when making financial decisions. This is not regulated advice and therefore the FCA is focusing on consumer understanding of what is regulated, and what is not.
  • Annex 1 firms: The FCA currently only has the power to look at how these firms are meeting their anti-money laundering obligations. Its conduct rules, consumer protections, SMCR and other powers do not apply.

Other issues remaining on the FCA’s radar include:

  • Universal right to bank account for companies: This year, the FCA is planning to review banks’ response to access to banking challenges and where improvements can be made for SMEs in key sectors including defence.
  • Financial Promotions – social media: The FCA wants to work with legitimate finfluencers providing helpful information for consumers so that they better understand the FCA’s rules and their obligations.
  • Deposit aggregators (savings platforms or savings marketplaces): The FCA is keeping this on the list of activities that might need to be brought into its perimeter, given the potential risk of consumer harm.

For further information on the FCA’s latest Perimeter Report, see this Our Thinking article.


United Kingdom: Government publishes Smart Data Strategy and FCA publishes Open Finance Roadmap

On 26 March 2026, the Department for Business and Trade (DBT) published the UK’s Smart Data Strategy (the Strategy) setting out the vision for smart data in 2035 and explaining the actions the government will take to achieve it, including investment of at least £36 million. The government is setting the target of five or more active smart data schemes by 2030 and 20 or more by 2035.

In line with the UK’s Industrial Strategy, the Strategy sets out the government’s next steps in priority “growth-driving sectors” including banking (payments), financial services, energy, property, and digital markets. This will include funding for industry-led smart data pilots. The government commits to working closely with industry groups that are progressing smart data, to ensure that any future regulations align well with existing and planned work. Annex A to the Strategy includes more detail on how the government and industry (and regulators) could work together/complement each other's work.

The Strategy also explains how the government will maximise the economic growth impact of smart data by exploring ways that smart data schemes could support cross-economy drivers of growth (for example, via a new cross-economy Smart Data Guidebook due in early 2027), such as the government's ambitions for AI adoption and innovation, complementing other data and digitisation policy (for example, on Digital ID), and through work with international partners.

The government has set out the following timeline:

  • From 2025 to 2027, actions include: long-term regulatory framework for Open Banking in place; roadmaps published for scheme in Financial Services.
  • From 2027 to 2030, actions include: five or more schemes including banking, fuels, energy, and finance; long-term plan for cross-sector governance; substantial private investment in smart data; more developed international cooperation and influence.
  • From 2030 to 2035, actions include: 20 or more schemes in sectors across the economy; a stable system of cross-sector governance and innovation support; extensive international cooperation and trade; continued monitoring, evaluation, and improvement; world-leading smart data industry driving growth.

Following publication of the government’s Smart Data Strategy, on 14 April 2026 the FCA published “Open finance roadmap: our vision for a smart data future” (the Roadmap), setting out a “clear path” to turn the potential for Open Finance to be the “next major step in the UK’s smart data revolution” into delivery between now and 2030.

The approach outlined in the Roadmap is described by the FCA as “pragmatic, evidence-led and collaborative”, and will draw on lessons from Open Banking and international experience to ensure that Open Finance is developed in a “secure, trusted and proportionate” way.

For more on the FCA’s Open Finance Roadmap, see this Our Thinking article.


United Kingdom: PSR publishes Annual Plan and Budget 2026/27

On 26 March 2026, the Payment Systems Regulator (PSR) published its Annual Plan and Budget for 2026/27.

In 2026/27 the PSR will focus on:

  • Taking action on card fees, including next steps on cross border interchange fees and implementing remedies on domestic scheme and processing fees to address weak competition.
  • Developing its cards markets strategy by considering its approach to competition in cards markets in the round, taking account of other market developments, to help in determining how best it can meet its competition objective, and support the FCA in determining the best way to regulate these markets going forward.
  • Continuing action to tackle APP fraud, including publishing and responding to the independent evaluation of the first year of mandatory reimbursement and monitoring how firms are meeting the standards expected of them.
  • As part of its core National Payments Vision work, overseeing the delivery of critical payments infrastructure, working closely with the Bank of England, HM Treasury and the FCA through the Payments Vision Delivery Committee.
  • Supporting the next phases of Open Banking, including work to establish a long-term regulatory framework and future oversight arrangements.
  • Strengthening supervision and enforcement, aligning approaches with the FCA to support effective oversight.
  • Delivering FCA/PSR consolidation planning that manages impact and provides clarity and certainty for regulated entities, enabling them to continue operating with confidence.

European Union: ECB publishes comprehensive Eurosystem Payments Strategy

On 31 March 2026, the European Central Bank (ECB) published a new, comprehensive Eurosystem Payments Strategy, designed to address the “ever-faster” pace of digitalisation and new technologies affecting payments. The Strategy focuses on digital payments, and use cases for wholesale, B2B, retail and cross-border payments. Cash aspects of payments are the subject of a separate Eurosystem Cash Strategy.

The overarching approach is to “improv[e] the existing payment infrastructures at the same time as catalysing and supporting new ones”, based on four strategic aims:

  • to ensure the effectiveness of monetary policy, financial stability and the smooth functioning of payment systems by maintaining the role of central bank money as the anchor of a two-tier monetary system;
  • to achieve strategic autonomy and increased resilience for European payments;
  • to foster an integrated, competitive and innovative payments ecosystem; and
  • to support the international role of the Euro.

These strategic aims involve:

  • Developing an integrated European market for tokenised settlement assets;
  • Improving the existing infrastructure and investing in Distributed Ledger Technology (DLT)-based solutions for wholesale payments;
  • Enhancing standardisation, automation and process integration in corporate payments;
  • Achieving resilient, integrated, innovative and competitive euro retail payments through the digital euro and market-led solutions; and
  • Advancing the G20 roadmap to enhance cross-border payments.

In terms of the next step, the Eurosystem will actively monitor developments and adapt its Strategy as needed.


United Kingdom: DRCF publishes Future of Agentic AI paper

On 31 March 2026, the Digital Regulation Cooperation Forum (DRCF), comprising the Competition and Markets Authority (CMA), FCA, Information Commissioner’s Office (ICO) and Ofcom, published a paper on the Future of Agentic AI, following a public call for views on agentic AI in Autumn 2025. The paper is described as a forward-looking exploration of agentic AI and how UK regulatory frameworks can help realise its opportunities in a responsible and safe way.

While all four regulators agree that AI agents do not fall outside existing UK regimes, with obligations around transparency, fairness, safety, consumer protection and competition continuing to apply as agentic AI develops, the paper considers potential future developments and shares early thoughts on cross-regulatory implications across four categories:

  • Governance: For example, clear thresholds should be defined for when an AI agent must seek human approval before proceeding.
  • Data protection and cybersecurity: For example, transparency about how personal data is used by agentic systems is critical to building consumer trust, ensuring agentic AI’s growth, and avoiding any systemic privacy vulnerabilities which could undermine confidence in digital services, destabilise markets and hinder innovation.
  • Consumer rights and interests: For example, consumer rights must continue to be upheld by agentic AI providers, including protections against false or misleading claims, requirements for minimum standards of quality and fitness for purpose, and safeguards against unfair contractual terms.
  • Market dynamics and competition: For example, harmful behaviour can arise at the network level, even if individual agents appear benign, making detection and attribution difficult. It also means collusion and manipulation could occur at scale. Adopting new monitoring, governance and detection tools could help regulators and firms manage these emerging risks.

During 2026/27, the DRCF is planning further horizon-scanning work, and further research into consumer attitudes towards AI (including agentic AI), and how regulatory tools can support trusted and safe adoption. All DRCF regulators are also pursuing further individual work on agentic AI within their remits.


United Kingdom: HM Treasury, Bank of England and FCA respond to Treasury Committee report on AI in financial services

On 16 April 2026, the House of Commons Treasury Committee published a report setting out responses from HM Treasury (HMT), the Bank of England (BoE) and the FCA to its January 2026 report on AI in financial services.

Among other things, the report includes the following points:

  • The existing approach to managing AI risks in the financial services sector is not a "wait and see" approach. It is risk based, proportionate and effective, designed to ensure AI is adopted safely. Firms have welcomed the approach and understand they are responsible for their AI use, including its impact on consumers.
  • Significant work is being carried out by HMT and the regulators to monitor AI developments, including through live testing, sandbox initiatives, supervisory engagement and horizon scanning. Their approach to AI is continually reviewed as the technology develops and the regulatory framework can be strengthened as needed.
  • Following the Committee's recommendation to produce practical guidance for firms, the FCA will share additional examples of good and poor practice as its innovation work progresses. It also refers to the AI Live Testing evaluation report, which it will publish at the end of 2026 or in early 2027.
  • The Financial Services AI Champions will play an important role in supporting the sector's safe and responsible adoption of AI by advising HMT and the regulators on emerging AI issues, which will inform policy and industry action.
  • HMT expects to make initial designation decisions on critical third parties in 2026. To protect the designation process and any potential outcomes, no further information will be released until the designations have been made.
  • The BoE is incorporating AI scenarios into cyber and operational resilience testing and examining the conditions under which AI agents trading in financial markets could demonstrate herding behaviour.

United Kingdom: Supreme Court rules on appointed representative liability under FSMA

On 1 April 2026, the Supreme Court handed down its judgment in an appeal concerning the extent of a principal's responsibility for the activities of its appointed representative (AR) under section 39 of Financial Services and Markets Act 2000 (FSMA).

The Supreme Court ruled unanimously that a principal firm was not liable under section 39(3) of FSMA for advice that had been given by its AR to retail clients in circumstances where the principal itself did not have permission to advise retail clients and had expressly prohibited its AR from giving advice to retail clients under the terms of the AR agreement. The principal firm had appointed the AR to undertake, on its behalf, the business of arranging and advising on investments.

For more on the Supreme Court's decision, see this Our Thinking article. 


United Kingdom: FCA publishes directions and form on regulating BNPL

On 2 April 2026, the FCA updated its webpage on regulating buy-now-pay-later (BNPL), also referred to as deferred payment credit (DPC), to announce the publication of directions and a notification form relating to the Temporary Permissions Regime (TPR) for DPC lenders.

The FCA will start regulating DPC on 15 July 2026 (Regulation Day). The TPR will allow firms that were carrying on DPC activity on 15 July 2025 to continue temporarily operating on and after Regulation Day.

The directions were made under Articles 7 and 12 of the Financial Services and Markets Act 2000 (Regulated Activities etc.) (Amendment) Order 2025 (SI 2025/859). They specify that:

  • Firms eligible for the TPR may complete a notification form to register for temporary permission from 15 May 2026. The last day on which firms can notify to register is 1 July 2026. The fee for the registration is £280.
  • Firms with temporary permission may apply on or after 8 July 2026 for a Part 4A permission or a variation of their existing Part 4A permission concerning DPC activities (a relevant application).
  • Firms with temporary permission have until 15 January 2027 (six months after Regulation) to make a relevant application.
  • Any firm that does not currently hold the necessary permissions and does not register for the TPR will not be permitted to enter new DPC agreements after Regulation Day.

Ukraine: NBU simplifies Open Banking payment initiation requirements

On 31 March 2026, the Board of the National Bank of Ukraine (NBU) approved an amendment to the Regulation on Open Banking in Ukraine, originally approved by NBU Board Resolution No. 80 on 25 July 2025.

Under the new rules, payment initiation service providers (PISPs) are no longer required to populate the payment instruction field for the “name of the recipient's payment service provider”. This responsibility has been transferred to the account servicing payment service provider (ASPSP), which will populate the information in line with existing regulatory requirements.

The amendment took effect on 3 April 2026 and is intended to simplify the use of open banking services for users.


Australia: RBA to remove surcharging, reduce interchange fees and increase fees transparency

On 31 March 2026, the Reserve Bank of Australia (RBA) published a Conclusions Paper setting out the final decisions of the Payments System Board (PSB) following the RBA’s Review of Merchant Card Payment Costs and Surcharging. Following a public consultation launched in July 2025, the PSB concluded that the proposed reforms would promote competition, efficiency, and the public interest. Key decisions include:

  • removing surcharging on debit, prepaid and credit cards on the eftpos, Mastercard and Visa card networks;
  • lowering caps on interchange fees paid by Australian businesses; and
  • increasing transparency over fees charged by card networks and payment service providers.

Most measures will take effect on 1 October 2026. An interchange cap on foreign cards and certain transparency reforms will follow on 1 April 2027 to allow sufficient implementation time.

The RBA plans to launch a further public consultation in mid 2026 on other areas of the retail payments system, including mobile wallets, three-party card networks, buy-now-pay-later services, and e-commerce platforms.


European Union: EBA publishes decision on harmonising NCA reporting of SEPA data

On 10 April 2026, the European Banking Authority (EBA) published a decision, dated 1 April 2026, which harmonises the way national competent authorities (NCAs) report data under the SEPA Regulation (EU) 260/2012.

Under Article 15(3) of the SEPA Regulation, payment service providers (PSPs) are required to report data annually to their NCA, including information on charges for credit transfers and payment accounts. To avoid duplicate reporting of the same PSP data by NCAs to both the European Commission and the EBA, the decision provides that NCAs should submit the data only to the EBA, on an annual basis by 9 October. The EBA will then make the data available to the Commission through its data collection infrastructure, the European Centralised Infrastructure of Data (EUCLID).

Article 5 of the decision amends the Annex to the EUCLID decision (EBA/DC/2020/335) to reflect the new reporting requirement, which applies with immediate effect.


Europe: The Payments Association publishes report on role of digital platforms in APP fraud prevention and the case for shared liability

On 25 March 2026, the Payments Association published a report entitled “The new origin of APP fraud: Evidence of digital platforms’ role and the case for shared accountability”.

The report concludes that, as APP fraud is not just a payments issue and most scams begin on digital platforms, marketplaces and messaging services, existing frameworks need to be adapted to reflect this. It calls on the UK government, EU policymakers, and regulators to introduce enforceable measures on scam advertising and platform accountability, including:

  • coordinated regulatory action on advertiser verification;
  • faster removal of fraudulent content;
  • structured intelligence sharing; and
  • clearer accountability and financial repercussions when platforms repeatedly fail to prevent scam exposure at source.

According to the report, if fraud is to be reduced at scale it is essential that where platforms operate systems that enable large-scale scam exposure, they should also be expected to play a proportionate role in preventing it.


United Kingdom: FCA publishes blog post on areas of focus for Consumer Duty board reports

On 16 April 2026, the FCA published a blog post by Jonathan Pearson, FCA Head of Consumer Policy, setting out the areas that firms need to focus on in their next Consumer Duty board reports.

As the third cycle of Consumer Duty board reports is due in Q3 2026, the FCA has published information on what it has learnt from firms' year 2 board reports. It asks firms to focus on the following in their next reports:

  • Clearly linking data to customer outcomes;
  • Monitoring outcomes delivered by third parties (to assist firms, the FCA intends to consult on changes to rules and guidance relating to distribution chains in 2026, and publish best practice examples of how firms are monitoring outcomes under the Duty;
  • Evidencing meaningful board challenge; and
  • Deepening assessment of consumer understanding and support.

United Kingdom: PRA publishes Business Plan for 2026/27

On 17 April 2026, the PRA published its Business Plan for 2026/27, setting out the work it will undertake to deliver its strategic priorities for the coming year (which remain the same as for 2025/26).

The Business Plan provides details of regulatory initiatives intended to advance each of the PRA’s priorities in the banking, insurance and multi-sector sections of the Business Plan, which include:

Banking sector

  • Small domestic deposit takers (SDDTs): The PRA intends to complete an off-cycle review of firm-specific Pillar 2 capital requirements and expectations for SDDTs before the SDDT capital regime takes effect on 1 January 2027.
  • Prudential treatment of cryptoasset exposures: The PRA will consult on implementation of the Basel Committee on Banking Supervision’s (BCBS) standard on prudential treatment of cryptoasset exposures following completion of the BCBS's targeted review of the standard (announced in November 2025).

Multi-sector

  • Overseas recognition regimes: The PRA intends to confirm its final rules on implementing HM Treasury's Overseas Prudential Requirements Regime (OPRR) for deposit-takers and designated investment firms, on which it consulted in February 2026.
  • Operational risk and resilience: Work will include reviewing systemic firms' operational resilience self-assessments to assess their cyber resilience capabilities to respond to severe disruptions.

Global: CPMI and IOSCO publish report on UK implementation of principles for financial market infrastructures

On 16 April 2026, the International Organisation of Securities Commissions (IOSCO) and the Committee on Payments and Market Infrastructures (CPMI) published a report on monitoring implementation of the principles for financial market infrastructures (PFMIs) in the UK.

The report sets out the conclusions and recommendations from a level 2 assessment of whether, and to what degree, the UK legal, regulatory and oversight frameworks (as at 30 September 2023) applied to systemically important payment systems (PSs), central securities depositories (CSDs) and securities settlement systems (SSSs) are complete and consistent with the PFMIs.

As there are separate frameworks for PSs and for CSDs and SSSs these were assessed separately. The assessment team found that:

  • The UK legal, regulatory and oversight frameworks for PSs were complete and consistent with the PFMIs.
  • Some improvements were needed in the UK legal, regulatory and oversight frameworks for CSDs and SSSs. While these frameworks were mostly complete and consistent with the PFMIs, there were areas where implementation was partly consistent or not consistent.

The summary response from the Bank of England that is included in the report states that it is pleased with the assessment outcomes. It outlines work carried out in the UK since the September 2023 assessment cut-off date, including introducing the Fundamental Rules for financial market infrastructures which are based on the PFMIs.

Chapter 3

Regulatory Developments: Digital Assets

expanded collapse

United Kingdom: FCA publishes consultation on perimeter guidance for cryptoasset activities

On 15 April 2026, the FCA published a consultation paper (CP26/13) on its proposals to amend its Perimeter Guidance manual (PERG) to clarify the scope of the cryptoasset activities that will be regulated under the new cryptoasset regulatory regime under the Financial Services and Markets Act 2000 (FSMA) and when permission will be needed to carry on those activities.

The proposed guidance also aims to provide clarity for firms transitioning from the current cryptoasset regime under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (SI 2017/692) (MLRs) to the new cryptoasset activities under FSMA.

The draft guidance is set out in a new chapter in PERG, designed to:

  • help firms to determine whether an activity is within the perimeter; and
  • provide guidance on the new specified investments and new regulated cryptoasset activities, including which permissions may be needed for certain business models and how certain exclusions operate.

The FCA will reflect any further legislative changes in the guidance before finalising it.

Appendix 1 to the consultation paper contains the draft Perimeter Guidance (Regulated Cryptoasset Activities) Instrument 2026, which sets out the proposed amended Handbook text.

The consultation closes on 3 June 2026. The FCA will publish its final guidance in September 2026.

The application period for firms wanting to carry on the new regulated cryptoasset activities is open from 30 September 2026 to 28 February 2027, and the new cryptoasset regulatory regime will apply from 25 October 2027.

For more on the FCA’s consultation, take a look at this Our Thinking article.


United Kingdom: FCA publishes new webpage on MLRs registration ahead of new FSMA cryptoasset regime

On 26 March 2026, the FCA published a new webpage, providing guidance to cryptoasset businesses on registration under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (SI 2017/692) (MLRs) in advance of the forthcoming cryptoasset regulatory regime under the Financial Services and Markets Act 2000 (FSMA).

Applications for authorisation under the FSMA cryptoasset regime will open on 30 September 2026, with the new regime expected to come into force on 25 October 2027. Until the FSMA regime begins, firms must continue to comply with the requirement to be registered under the MLRs. The FCA recognises that some firms may wish to begin trading before the FSMA cryptoasset regime takes effect and may therefore seek MLRs registration first. The FCA has accordingly provided the following guidance, dividing applications for MLRs registration into three categories:

  • Applications submitted before 30 September 2026 (when the FSMA gateway opens): Applications will be assessed as normal. If an application has not been determined by this point, the firm will need to decide whether to apply for FSMA authorisation. The FCA will determine MLRs registration and FSMA authorisation applications separately, even where they are assessed concurrently.
  • Applications submitted on or after 30 September 2026: Once the FSMA gateway opens, the FCA will encourage firms to prioritise securing FSMA authorisation. Firms that still wish to apply for MLRs registration after this date should contact the FCA’s pre application support service (PASS) to explain their business plans and reasons for seeking registration. The FCA will accept information submitted as part of a firm’s FSMA authorisation application as relevant to its MLRs registration application, and only a single application fee will apply.
  • Applications submitted after 31 July 2027: The FCA has three months to determine MLRs registration applications, starting from receipt of the application form (or any further information required). As applications submitted after this date are unlikely to be determined before the FSMA cryptoasset regime comes into force, firms intending to become FSMA authorised are therefore advised not to apply for MLRs registration.

United Kingdom: HM Treasury publishes draft Money Laundering and Terrorist Financing (Amendment) Regulations 2026

On 26 March 2026, HM Treasury published a draft of The Money Laundering and Terrorist Financing (Amendment) Regulations 2026, together with an explanatory memorandum. The draft Regulations will revise the due diligence requirements in relation to cryptoasset businesses, large or complex transactions, high-risk jurisdictions and pooled client accounts.

Following a technical consultation in 2024, the draft Regulations propose amendments to the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (SI 2017/692) (the MLRs), including:

  • Narrowing mandatory enhanced due diligence to high-risk jurisdictions according to the FATF’s “Call for Action” list, and “unusually complex” transactions (rather than just “complex”);
  • Strengthening the anti-money laundering regime for cryptoasset businesses by aligning the MLRs with the new financial services regulatory framework for cryptoassets as established under the Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2026;
  • New provisions relating to insolvent bank customers, permitting credit institutions, in limited circumstances, to establish a business relationship and allow transactions to take place prior to completion of full customer due diligence;
  • Changes to the Trust Registration Service, including extending registration and data sharing requirements to certain non UK trusts that acquired UK land before 6 October 2020 and continue to hold it, introducing a de minimis exemption for certain low value non taxable trusts, and removing Stamp Duty Reserve Tax as a standalone trigger for registration; and
  • Replacing references to euros with pounds sterling, generally on a 1:1 basis.

The Regulations would come into force the day after they are made.


United Arab Emirates: VARA introduces rules for crypto exchange-traded derivatives in Dubai in Exchange Services Rulebook Version 2.1

On 31 March 2026, Dubai's Virtual Assets Regulatory Authority (VARA) published Version 2.1 of its Exchange Services Rulebook, formally introducing a regulatory framework for crypto exchange‑traded derivatives (ETDs) for the first time. The rules apply to all licensed Virtual Asset Service Providers (VASPs) offering exchange services in Dubai.

The new rules cover client suitability and classification, leverage controls, asset segregation, disclosure standards, and VARA's intervention powers.

Stricter rules have been established to protect retail investors, including limiting retail leverage to a maximum of 5:1, requiring a minimum of 20% initial margin, mandating suitability assessments before onboarding retail clients, and requiring firms to restrict access where products fall outside a client's risk profile. In addition, VARA retains broad emergency intervention powers, including suspending products, requiring position liquidations and increasing margin requirements, and may act without prior notice. 


Canada: Government announces key legislation relating to new stablecoin and open banking frameworks has received Royal Assent

On 26 March 2026, the Canadian government announced that Bill C-15, the Budget Implementation Act, 2025, No. 1 (the 2025 Budget Act), had received Royal Assent.

The 2025 Budget Act expands the supervisory mandates of the Bank of Canada to include:

  • Supervision of stablecoin issuers under the Stablecoin Act’s new federal stablecoin framework to regulate the issuance of fiat-backed stablecoins in Canada by both domestic and foreign issuers (expected to come into force in 2027); and
  • Oversight of the framework for consumer-driven banking (or open banking) under the Consumer-Driven Banking Act.

Further details of the new federal stablecoin framework can be found on this government webpage. For more on the new consumer-driven banking regime, see this government webpage.

The Department of Finance will continue to work closely with the Bank of Canada on developing supporting regulations for both of the new regimes. These will be subject to consultation before being finalised.


United States: FDIC approves notice of proposed rulemaking to establish GENIUS Act requirements for permitted payment stablecoin issuers and insured depository institutions

On 7 April 2026, the Federal Deposit Insurance Corporation (FDIC) Board approved a notice of proposed rulemaking to implement the Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act.

The proposed rule would establish requirements and standards applicable to FDIC‑supervised permitted payment stablecoin issuers (PPSIs) and insured depository institutions (IDIs) engaged in payment stablecoin-related activities. In particular, it would set out authorised and prohibited PPSI activities, require PPSIs to maintain identifiable reserve assets and generally require the redemption of payment stablecoins within two business days. The proposed rule would also clarify deposit insurance coverage for deposits held at IDIs that serve as reserves of a PPSI's payment stablecoin and address tokenised deposits.

Public comments will be accepted for 60 days following publication in the Federal Register

Chapter 4

Market Developments

expanded collapse

North Africa: Noah and VaulFi launch first direct-to-bank stablecoin bridge

On 26 March 2026, Noah announced a partnership with premier stablecoin-powered neobank VaulFi to launch the first direct‑to‑bank stablecoin bridge for North Africa. The collaboration will enable freelancers and businesses to receive international payments in under two hours, compared with the traditional 21‑day SWIFT settlement cycle. It also aims to address the “Triple Extraction Problem”, caused by a combination of high commissions, predatory foreign exchange rates, and a widening 80% gap between official and parallel currency markets. The partnership will reduce transaction costs from 12% to as low as 1%, and allow users to generate EUR (IBAN) or USD virtual accounts, with incoming fiat instantly settled as stablecoins backed by EUR or USD. 


Saudi Arabia: Lean Technologies becomes first licensed open banking provider

On 27 March 2026, it was reported that Lean Technologies, the MENA-based financial infrastructure provider, had become the first recipient of a Major Payment Institution licence from the Saudi Central Bank, allowing it to provide Open Banking services in Saudi Arabia. This marks a defining moment for Saudi Arabia's financial sector, with Open Banking transitioned from the regulatory sandbox testing phase to a licensed activity. Lean Technologies connected over one million bank accounts and analysed over one billion transactions during the testing phase, supporting institutions across buy-now-pay-later, consumer finance, automotive, investment and government services. This transition aligns with Saudi Vision 2030 objectives, under which a licensed and proven Open Banking sector represents a core component of its financial infrastructure.


Europe: Klarna partners with EuroParcs to offer flexible payment options for holiday bookings

On 27 March 2026, it was reported that Klarna had partnered with EuroParcs, one of Europe's fastest-growing holiday park operators, to introduce flexible payment options for holiday park stays in Germany, Austria, the Netherlands and Belgium. Under the partnership, customers booking holidays through EuroParcs can choose from a range of payment options, such as paying upfront, deferring payment, or paying in instalments, depending on their country. The collaboration reflects growing demand for flexible payment solutions in the travel and leisure sector and aims to make booking as pleasant and guest friendly as possible.


Europe: Visa Direct partners with Moonrise by Lunar to expand local payment access across the Nordics

On 27 March 2026, Visa Direct and Moonrise by Lunar announced a partnership to expand access to local payment rails and virtual accounts across Denmark, Sweden and Norway, powered by Nordic challenger bank Lunar. The collaboration enables Visa Direct to integrate Moonrise's local accounts and payment infrastructure, including virtual accounts, pay-ins and pay-outs, through a single API. This strengthens Visa Direct's ability to deliver real-time domestic payments and local account access for clients operating in or entering the Nordic region. The partnership builds on the existing relationship between Lunar and Visa, evolving it into a complete, scalable payment offering for clients across the Nordics.


United Kingdom: Revolut enrols all UK cards into Click to Pay

On 27 March 2026, it was reported that Revolut had automatically enrolled all UK-issued cards into Click to Pay, which is jointly operated by the major global card schemes. While Click to Pay offers a secure checkout experience, leveraging tokenisation and biometric authentication to protect consumer data, adoption remains low, with GlobalData data showing that only 4% of online shoppers in the UK have ever used a Click to Pay checkout. This suggests barriers beyond availability, including low consumer awareness and limited merchant integration. This initiative aims to increase adoption and forms part of a broader industry effort to position Click to Pay as a credible competitor to established digital wallets such as Google Pay. 


Global: Thunes launches instant cross-border payouts for gig and remote workers

On 30 March 2026, Thunes announced the launch of a direct-to-workforce cross-border payout solution designed to enable businesses to pay remote overseas teams, freelancers and gig workers instantly, 24/7. Accessible via a single API, the solution supports real-time payouts to bank accounts, mobile wallets and stablecoin wallets across 140 countries. It addresses  challenges associated with slow and fragmented international payment systems, particularly for global gig workers who prioritise rapid access to earnings. By connecting directly to local payment schemes including M-Pesa, Alipay and GCash, and offering stablecoin payouts in markets with volatile local currencies, Thunes aims to improve payment speed, transparency, and reliability for the global economy. 


Global: Nium launches dual‑network stablecoin card issuance platform

On 30 March 2026, Nium announced the launch of a stablecoin card issuance platform that enables businesses holding stablecoins to issue cards on both the Visa and Mastercard networks through a single API integration. The platform enables stablecoin settlement options, reducing multi‑step fiat conversion chains and operational friction, while maintaining compliance through Nium's own regulatory licences in over 40 countries. By pairing card issuance with Nium's payout network covering more than 190 countries, this enables companies to deploy stablecoin balances via cards and payouts without managing separate provider relationships. Nium aims to reduce time‑to‑market for stablecoin card programmes from months to days.


United States: SoFi launches Big Business Banking to support fiat and crypto banking on a single regulated platform

On 2 April 2026, SoFi Technologies, Inc. (SoFi) announced the launch of SoFi Big Business Banking, a new platform that enables enterprise partners to manage both fiat and crypto banking from a single, nationally chartered bank. Combining the strength of a nationally chartered bank and direct access to the Federal Reserve with modern, API-driven capabilities, SoFi Big Business Banking aims to create a simpler and faster way for companies to make payments, access liquidity, and operate at scale in real time. The new platform will support regulated business deposit accounts, real-time, API-driven payments, digital asset enablement, and unified financial operations. Supported by industry leaders, initial participants include Cumberland, Bullish, BitGo, B2C2, Fireblocks, Wintermute, Galaxy, Jupiter, Mesh Payments and Mastercard. 


Global: UnionPay launches Agentic Payment Open Protocol framework

On 3 April 2026, it was reported that UnionPay had launched the Agentic Payment Open Protocol (APOP) framework, which leverages UnionPay's platform capabilities and neutrality to support agentic payments. The framework establishes a unified trust and interaction model for agents, merchants, financial institutions and technology platforms. APOP is built on four core capabilities: lifecycle management of agent identity, end-to-end intent management, streamlined user identity management and comprehensive payment authorisation services. Emphasising openness and interoperability, UnionPay aims to build an open and trusted smart payment ecosystem.


Vietnam and China: NAPAS, Vietcombank and Ant International launch cross-border QR payment service

On 3 April 2026, Vietnam National Payment Corporation (NAPAS), Joint Stock Commercial Bank for Foreign Trade of Vietnam (Vietcombank) and Ant International announced the launch of a cross-border QR payment service between Vietnam and China. Through the new service, Chinese tourists can use the Alipay e‑wallet to scan VietQR Global codes and pay at merchants across Vietnam, including retail stores, restaurants, hotels and tourist sites. Transactions are processed via connectivity infrastructure between NAPAS and Ant International, with clearing and settlement handled by Vietcombank, allowing direct payments between the Chinese Yuan (RMB) and the Vietnamese Dong (VND). The initiative aims to enhance tourist experience and expand opportunities for Vietnamese businesses. 


Asia: Mastercard advances ASEAN's AI‑driven payments with authenticated agentic transactions and AI Centre of Excellence

On 6 April 2026, Mastercard announced a major expansion of its AI strategy in ASEAN with the successful rollout of authenticated agentic transactions across multiple markets and plans to establish a new AI Centre of Excellence (CoE) in Singapore. Initial pilots of the authenticated agentic transactions in Singapore and Malaysia demonstrate the region's readiness for secure, AI‑enabled commerce. The framework combines tokenised credentials, verifiable intent and end‑to‑end auditability to ensure transactions remain consumer‑authorised and transparent. Mastercard's upcoming CoE will bring together its innovation hub, cybersecurity capabilities and AI expertise to strengthen innovation, governance and readiness for AI powered payments across Southeast Asia.


Switzerland: Six Swiss banks launch joint CHF stablecoin sandbox with Swiss Stablecoin AG

On 8 April 2026, major Swiss banks including UBS, PostFinance, Sygnum, Raiffeisen, Zürcher Kantonalbank and BCV announced the launch of a stablecoin sandbox with Swiss Stablecoin AG to test potential use cases for a Swiss franc (CHF) stablecoin in Switzerland. The sandbox will explore how blockchain applications can be linked to CHF, addressing the current absence of a regulated CHF stablecoin with broad application in Switzerland. The sandbox will be conducted in 2026 and is open to additional banks and institutions, with Swiss Stablecoin AG providing the technical infrastructure for issuing the stablecoin. The initiative seeks to strengthen the Swiss digital money ecosystem and enhance the competitiveness of Switzerland's financial centre.


Bahrain: MoneyHash partners with EazyPay to strengthen presence in Bahrain

On 7 April 2026, MoneyHash announced a partnership with Eazy Financial Services (EazyPay), a Central Bank of Bahrain–licensed payment service provider and acquirer. The partnership will strengthen MoneyHash's ability to support merchants operating in Bahrain. Through the collaboration, businesses can align with a licensed local acquirer offering a wide range of payment acceptance capabilities and emerging digital payment options, including smart POS devices, SoftPOS solutions, online payment gateway services supporting debit and credit cards, and digital wallets. This provides access to payment gateways in Bahrain and supports interoperability with digital banks, helping merchants operate with greater flexibility across evolving payment ecosystems.


United States: Paysafe launches Pay with Crypto for iGaming operators in partnership with MoonPay

On 7 April 2026, Paysafe announced the launch of Pay with Crypto, a new crypto payment method for iGaming operators and daily fantasy sports brands in the United States, developed in partnership with MoonPay. Pay with Crypto allows players, where permitted, to fund accounts using preferred cryptocurrency or stablecoin, which is instantly converted into U.S. dollars to allow play. Addressing strong consumer demand for crypto payments, the product enables players to connect their wallets directly or via QR codes. Operators also benefit from flexible settlement options in stablecoins or any fiat currency through a single, streamlined integration of the Paysafe Gateway.


Asia: 8B and PayU partner to connect India's payment rails to Central Asia

On 8 April 2026, 8B, a Central Asian fintech infrastructure company, announced a partnership with PayU, India's leading diversified fintech platform. The collaboration will enable Indian payment methods, including UPI, Net Banking, and Indian debit and credit cards, across Central Asia. By integrating PayU's APIs into 8B's merchant network, Indian tourists can pay seamlessly at merchants in Kazakhstan, Uzbekistan, Kyrgyzstan, and the broader region using familiar domestic payment tools. Beyond tourism, the partnership supports cross-border trade by reducing payment friction and improving conversion at checkout. According to the announcement, this collaboration represents a significant step in strengthening digital payment infrastructure between the two economies, establishing the first structural bridge to support growing trade and tourism.

Chapter 5

Surveys and Reports

expanded collapse

Global: Global Payments publishes report highlighting continued card dominance alongside rapid growth in digital wallets

On 31 March 2026, Global Payments (formerly WorldPay) released a report analysing consumer and business payment preferences across 42 global markets. The report finds that, while cards continue to dominate both online and in store spending, generational shifts and digital first preferences are expected to accelerate the transition towards digital wallets over the coming years.

Key findings and statistics include:

  • Regional contrasts: In 2025, direct card use accounted for 49% of online spending and 71% of in store spending in the United States, compared with 31% and 48% respectively at the global level. In the Asia Pacific region, cards represented just 15% of online spending and 20% of in store spending in 2025, highlighting a much stronger shift towards mobile based payments.
  • Digital wallets gaining share: In 2025, digital wallets accounted for 40% of U.S. online spending and 17% of in store spending, with wallet spending forecast to grow by around 10% annually through to 2030. By 2030, digital wallets are projected to account for USD 4.1 trillion of U.S. spending, representing a 64% increase from 2025 levels.
  • Generational divide: Digital wallets are already the most used online payment method for 39% of consumers aged 18–24 and 41% of those aged 25–34, indicating that Gen Z and younger millennials are driving long term change in payment behaviour.

Global: Visa publishes Business to AI Report

On 2 April 2026, Visa published its Business to AI (B2AI) report, which shows that AI is beginning to act as an active participant in commerce rather than solely a supporting tool. Visa describes this emerging model as B2AI, in which AI agents evaluate, negotiate, and transact on behalf of humans, who remain accountable for outcomes.

Business readiness for AI driven commerce is strong, with 77% of businesses already using or piloting AI and 71% willing to optimise products and services specifically for AI agents. On the consumer side, acceptance is increasing, though trust remains critical: 38% of consumers are comfortable with AI completing a purchase, and trust rises significantly when financial institutions are involved, with 35% trusting payment network enabled AI.

The report emphasises that building trust, transparency, and effective human override mechanisms will be essential to the successful adoption of AI mediated commerce.


Global: The Payers publishes Global Stablecoins Report 2026

On 25 March 2026, the Payers published its Global Stablecoins Report 2026, examining how stablecoins are transforming the payments landscape and the implications for the broader financial system.

The report finds that stablecoins are becoming a structural component of global payments rather than a peripheral digital asset. Stablecoin market capitalisation is approaching USD 317.9 billion in 2026 and could exceed USD 2 trillion as institutional adoption accelerates.

As a result, the report suggests that banks should focus on integrating stablecoins alongside deposits and settlement systems while managing regulatory change. Merchants are encouraged to assess the operational, cost, and acceptance benefits, while payment service providers may use stablecoins to redesign payment orchestration, compliance, and risk frameworks.

Overall, the report emphasises the importance of anticipating developments rather than reacting to them, noting that institutions with flexible strategies will be best placed to benefit from the evolution of digital payments.

The report concludes that stablecoins will complement, rather than replace, traditional payment systems.

 

 

Authored by Charles Elliott, Virginia Montgomery, and Mengze Han.

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