Great expectations: a short history of the UK National Payments Vision

On 14 July 2026, the UK government published its consultation on “Modernising payments services regulation”. The consultation discusses potential legislative changes to the body of assimilated law which sets out UK regulatory requirements for payment services and electronic money (e-money).

Legislative changes flowing out of the consultation will write the next chapter in the development of the UK’s National Payments Vision (NPV). So, what has been the story of the NPV so far and how does this latest consultation move the vision forward?

Future of Payments report (November 2023)

The NPV started as a twinkle in Joe Garner’s eye. In 2023, Mr Garner, former CEO at Nationwide Building Society, was asked by the government to carry out a review into the future of retail payments in the UK. The terms of reference for the review set out three key questions:

• What are the most important consumer retail payment journeys both today and in the next 5 years?
• For these journeys today, how does the UK consumer experience for individuals and businesses compare vs other leading countries?
• Looking at the in-flight plans and initiatives across the payments landscape, how likely are they to deliver world leading payment journeys for UK consumers?

Garner’s final report noted that more could be done both to simplify the consumer interface and security protocols for account-to-account payments and to encourage the use of account-to-account payments between consumers and merchants in a market currently dominated by card-based payments. The report noted that Open Banking had the potential to catalyse account-to-account payments but that, to do so, Open Banking needed to be placed on a sustainable commercial footing and provide access to a consumer-friendly dispute resolution process. There were also calls to tackle the complex interactions between multiple financial regulators in the payments space and to explore how regulatory change applying to smaller, innovative fintechs could be streamlined and better communicated.

However, the primary recommendation coming out of the Garner Review was that, to optimise the combined impacts of a plethora of in-flight payments development initiatives, the UK government should develop a National Payments Vision and Strategy to bring clarity and direction to its future desired outcomes for UK payments.

National Payments Vision (November 2024)

The resultant UK government NPV was born just a year later. The NPV aspired to a “trusted, world-leading payments ecosystem delivered on next generation technology, where consumers and businesses have a choice of payment methods to meet their needs.”

Core priorities drawn out in the NPV included UK payments regulation which is “clear, predictable and proportionate”. Payments must be backed by modern, reliable infrastructure which leverages the latest technology. In guiding the future UK payment landscape, the NPV set overall direction based around three pillars:

• Innovation
• Competition
• Security.

Key initiatives championed in the NPV included driving innovation in account-to-account payments and Open Banking and continuing research into a potential Central Bank Digital Currency (CBDC). Innovation in payments should be underpinned by the principles of fair and affordable access to data, with Open Banking offering plausible commercial models for all parties involved, including for the banks currently providing data access. 

Consumer trust in payment systems was flagged as paramount. Preserving this required system reliability, access to consumer help when things go wrong and proactive measures to tackle fraud, over and above the promised review of the Payment System Regulator’s (PSR’s) Automated Push Payment fraud reimbursement regime.

The NPV saw delivering the right payments infrastructure as requiring a more flexible and agile approach. That approach was to be spear-headed by a new regulator-led Payments Vision Delivery Committee (PVDC). The PVDC was tasked in its terms of reference with setting out an approach both for the development and delivery of the UK’s retail payments infrastructure needs and for the required governance and funding model to achieve it, including proposals for the reform of Pay.UK. Within a year, the PVDC should also publish a sequenced plan of broader future payments initiatives - the Payments Forward Plan.

Stakeholder engagement for the NPV was to be coordinated through a dedicated Vision Engagement Group comprising public and private membership. Private sector participation in the Vision Engagement Group would be subject to an open application process and reflect the breadth of the stakeholder landscape – including financial services providers, fintechs, merchants and consumer representatives.

HM Treasury regulatory remit letter on payments (November 2024)

The NPV was accompanied by an H M Treasury November 2024 remit letter to the Financial Conduct Authority (FCA) and PSR setting out the UK government’s priorities for economic growth and for development of the payments sector. The letter reiterated support for the further development of Open Banking, consumer protection from fraud, a fresh approach to the renewal of UK retail payments infrastructure and enhanced regulatory coordination.

Regulatory coordination and renewal of the institutions underpinning governance of the NPV was to emerge as the predominant NPV theme for 2025.

Merger of the PSR into the FCA announced (March 2025)

On 11 March 2025, as part of its Regulation Action Plan, the UK government announced its intention to merge the PSR and its functions into the FCA. The government attributed the move to “complaints from businesses that the regulatory environment was too complex – with payment system firms having to engage with three different regulators, costing them time, money and resource”.  The PSR responded, describing the move as a “pragmatic next step in simplifying and clarifying payments regulation”.

In June 2025, the payment regulators themselves revisited coordination issues, pending the UK government bringing forward legislative proposals to merge the PSR into the FCA. A revised Memorandum of Understanding between the Bank of England, FCA, PSR and Prudential Regulation Authority (PRA) was published.

Consultation proposals to achieve the merger were then brought forward in September 2025 in, “A Streamlined Approach to Payment Systems Regulation”. The consultation closed in April 2026, with the outcome confirming plans to table primary legislation to effect integration of the PSR into the FCA.

Payments Vision Delivery Committee update and Strategy for future retail payment infrastructure (July, November 2025)

The PVDC reported back with an innovative model for delivering the next generation of UK retail payments infrastructure. The PVDC would continue to set overarching strategy but a new body, the Retail Payments Infrastructure Board (RPIB) would translate that strategy into design. Chaired by the Bank of England and involving both regulator and industry input, the RPIB would convene expertise across the sector and resolve gridlocks where needed. The Board would oversee both continued operation of existing payments systems by Pay.UK and a new Delivery Company, an industry-led entity tasked with procuring and funding next generation infrastructure.

The PVDC then set out its overall Strategy for future retail payment infrastructure. The Strategy aimed to reflect the NPV pillars of innovation, competition and security. It coalesced around 5 strategic outcomes:

• Greater choice of innovative and cost-effective payment options
• Seamless payments with interoperability in a multi-money ecosystem
• Trust and protection from fraud and wider crime
• Fair, transparent and non-discriminatory access to harness innovation and competition
• Operational and financial resilience.

Payments Forward Plan and FCA Payments Priorities report (February, March 2026)

In 2026, institutional capacity-building began to give way to creation of a tangible, medium-term roadmap for the NPV.

First came the Payments Forward Plan (PFP) envisaged at the launch of the NPV. Resembling a dedicated payments version of the Regulatory Initiatives Grid, the PFP set out payments-related regulatory projects to be undertaken over the next 3 years, echoing Joe Garner’s original call to tackle congestion and reduce noise around regulatory change for payments firms.

Supplementing the PFP, the FCA published its own report highlighting its regulatory and supervisory priorities for the payments sector. Alongside asking firms to get ready for the future through managing change and investing in operational resilience, the themes of consumer protection and trust shone through. There was an emphasis on firms delivering the FCA’s required improvements to safeguarding in the payments and e-money sectors set out in PS25/12 (August 2025) and continuing to be guided by the FCA’s flagship Consumer Duty policy. 

RPIB consultation on design of future retail payments infrastructure (June 2026)

The RPIB also took its first steps to shape system design compatible with the PVDC’s strategic outcomes. It launched a consultation on the future retail payments architecture which includes an indicative roadmap towards next-generation payments infrastructure and invites responses on a future model from three perspectives:

• future payment journeys
• design principles
• the wider payments ecosystem.

The consultation closes on 11 September 2026.

UK government: “Modernising payments regulation” consultation (July 2026)

Then we come back, full circle, to the current UK government consultation on changes to assimilated law on payment systems and e-money.

The consultation builds on the institutional and strategic foundations which have been laid for the NPV by drawing together the legislative changes needed to cement it. In doing so, the consultation completes the last piece of the jigsaw in the creation of the regulatory framework needed to drive forward the NPV.

Updating existing regulation (Chapter 2): The UK government discusses striking the right balance between legal certainty and flexibility in deciding whether to repeal assimilated law and replace it with FCA regulatory rules. It favours the payments regulatory perimeter and key consumer protection (such as notice periods for payment users when their framework agreement is terminated) being retained in legislation, whilst believing that prescriptive technical standards such as on Strong Customer Authentication (SCA) would serve innovation better if replaced with outcomes-based regulatory requirements.

New developments in payments (Chapter 3): Tokenised deposits and stablecoins have the potential to transform the UK financial landscape. In principle, the UK government considers that digital deposits and domestically issued stablecoins used for payments should be regulated in the same way as traditional sterling deposits and payments. This would require the inclusion of stablecoin payments under UK payments regulation, with accompanying tailored exclusion from aspects of the new FCA crypto-asset regulatory regime. Future developments may require re-organisation of the regulated activities associated with payments and e-money. Consideration should be given to facilitation of agentic artificial intelligence (AI) in payments and to ongoing oversight of sectoral risks such as financial inclusion, resilience and individual accountability.

Open Banking (Chapter 4): Finally, the consultation discusses the legislative framework needed to support a sustainable commercial model for Open Banking and future regulatory oversight of Open Banking activities.

From vision to action

In a little under three years from Garner’s statement of the problem, the NPV has emerged as the core articulation of a shared ambition for a best-in-class end state for UK retail payments. 

Capacity-building for the NPV has kick-started a reimagining of the institutional structures charged with its governance and the instigation of an inclusive, strategic planning process. Modernising the legal framework for payments will put in place the last foundation stone before the NPV moves on to the all-important execution phase.

We must wait to see if the UK NPV’s goal of a “trusted, world-leading payments ecosystem delivered on next generation technology” will be fully realised. However, what we can already say is that the NPV has given much-needed momentum and drive to UK aspirations to lead the way in retail payments. As Antoine de Saint-Exupéry, author of ‘The Little Prince’, famously quipped "A goal without a plan is just a wish."