Separate proposals from obligations
Proposal: HM Treasury opened a 12-week consultation on 14 July covering the Payment Services Regulations, Electronic Money Regulations, tokenised and agentic payments, Open Banking access rights, commercial scheme pricing and the Future Entity. Responses close on 6 October. None of these proposals is yet a new firm obligation.
In force: direct oversight of the first four critical third parties began on 13 July, while regulated firms retained their existing outsourcing and operational-resilience responsibilities.
In force: third-party Deferred Payment Credit agreements entered from 15 July are regulated credit agreements. Lenders must hold the relevant authorisation or temporary permission and follow FCA rules. Merchant broking remains exempt.
The decision for product, engineering and compliance teams is immediate even where the law is not. Map which Treasury questions affect your operating model, record ownership across AI-assisted and deterministic payment steps, and test whether supplier evidence supports the recovery outcomes you already promise.
Read the Treasury consultation →18.81 million reported user connections
Treat the return redirect as navigation, not payment truth
Read asima_payment_id from the return URL, then verify the payment server-side with GET /v1/payments/{id}. Do not fulfil from the redirect alone, and do not treat Authorised as the final state. Configure a webhook for asynchronous changes because settlement can follow the customer’s return. Store both the Asima payment ID and your merchant payment reference so every update can be reconciled.
Asima payments guide →Two consultation dates belong in the delivery plan
11 September: responses close on the Bank of England-led design for the next generation of UK retail payments infrastructure. 6 October: Treasury’s modernisation consultation closes. By the end of 2026, the government has committed to lay a statutory instrument under the Data (Use and Access) Act for the long-term Open Banking framework. The FCA also expects to consult on that framework by year end, subject to legislation.
Three more worth reading
Modernising payment services regulation: what Open Banking teams need to decide
A decision-led guide to Treasury's proposals on access, pricing, governance, tokenised payments and agentic payments.
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Agentic payments architecture: separating intelligence from execution
A practical boundary between probabilistic AI orchestration and deterministic authorisation, policy and execution controls.
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Building payments infrastructure for the next decade
A framework for judging retail-payment infrastructure by resilience, interoperability and adaptability rather than by a single payment method.
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