Open banking takes next step forward with launch of UK Payments Initiative scheme

What Changed

• - The FCA publicly endorses the launch of the UK Payments Initiative (UKPI) as an industry‑led open banking payments scheme focused on commercial variable recurring payments (cVRP), signalling regulatory support and expectation of market adoption.
• The statement confirms the FCA wants competition between commercial open banking schemes, indicating a shift from a single mandated model (under PSD2/open banking implementation) towards multiple competing schemes governed by industry standards under
• The FCA signals support for the creation of an independent standards‑setting body for open banking payments, moving standard‑setting away from transitional arrangements towards a more permanent, industry‑wide governance structure.
• The FCA announces its intention, subject to future legislation granting new powers, to consult on a long‑term regulatory framework for open banking (and, by extension, commercial open banking schemes such as UKPI) by the end of 2026.
• The FCA links this announcement to its regulatory roadmap for open finance, confirming that open banking data‑sharing will be extended to broader financial data, providing a strategic direction of travel that firms should factor into their medium‑ter
• The FCA frames UKPI and the roadmap as a means to give consumers and businesses greater control over financial data and more choice in how they pay for recurring goods and services, underscoring expectations around consumer protection, transparency,

Suggested Considerations

• Conduct an internal assessment of how your firm currently uses or plans to use open banking and cVRP (e.g., recurring payments, subscription billing, merchant acquiring) and document potential exposure to UKPI or similar schemes.
• Establish or update a regulatory horizon‑scanning process to track: (i) UKPI scheme documentation and rulebooks, (ii) FCA’s forthcoming open finance regulatory roadmap outputs, and (iii) the enabling legislation that will grant the FCA new powers.
• Engage product, legal and compliance teams to map existing recurring payment processes and consumer consent flows against anticipated expectations for open banking cVRP, including clarity of consent, cancellation rights, transparency of variable amounts, and dispute handling.
• Review and, where necessary, update data protection, API security, and customer authentication controls to ensure they can support commercial open banking schemes and more granular data‑sharing under an open finance regime.
• For firms intending to participate in UKPI, proactively review and align internal policies with emerging industry standards and scheme rules, including technical standards, liability allocation, service‑level requirements, and complaints/chargeback processes.
• Update governance frameworks so that Senior Managers and board‑level committees receive regular reporting on open banking/open finance developments, including UKPI adoption, emerging standards‑setting bodies, and future FCA consultations.

Key Dates

Who is Affected