Consultation Watch: Open banking and payments · UK / EU

HM Treasury's payments overhaul closes tomorrow, 6 October: open banking access, pricing and FCA powers all on the table

Read broadly as open banking, account-to-account and wider payment services regulation for a mid-size payment institution. This week is UK-heavy: one consultation closes tomorrow, and I found no open EU consultation on the topic from the EBA or European Commission.

The 30-second version
  1. HM Treasury's Modernising Payment Services Regulation consultation closes 11:59pm, 6 October 2026, and covers open banking access rights, pricing and FCA powers.
  2. Bank of England fee regime for recognised payment systems closes 22 October 2026; the FRC's safeguarding audit standard draft closes 26 November 2026.
  3. EU: no open payments consultation confirmed on primary portals this week; PSD3/PSR is in formal adoption, not consultation.
01HM Treasury · Oct 6

HM Treasury asks 39 questions on rewriting UK payments and open banking rules

Open consultation, UK. Published 14 July 2026; closes at 11:59pm on 6 October 2026 (time zone not stated on the page). Tomorrow is the last day.

The paper proposes moving more detailed payment-services requirements from the Payment Services Regulations 2017 and E-Money Regulations into FCA rules, and sets out a long-term open banking framework with powers delegated to the FCA under the Data (Use and Access) Act 2025. Questions most relevant to account-to-account business: a new right of access for variable recurring payments (Q21); whether ASPSPs may charge third parties for access currently free (Q22); lifting the contract ban (Q23); whether PISP and AISP definitions are fit for purpose (Q25); FCA powers to mandate participation in commercial open banking schemes (Q29) and to intervene in access pricing (Q34); and regulating the Future Entity as an interface body (Q32). Other chapters cover tokenised and agentic payments, stablecoins in the payments perimeter, and senior manager accountability for financial crime risk (Q19).

How to respond: email [email protected], or write to Payments & Fintech team, HM Treasury, Horse Guards Road, SW1A 2HQ. The page lists no response form; I did not find a confidentiality statement in the text I reviewed, so check the full paper before sending commercially sensitive material. The FCA Consumer Panel has also published a response, which is an organisation's response and may be cited.

For a mid-size A2A payment institution: send at least a short email by deadline on access pricing, VRP scope and permission variation costs (Q11, Q21, Q22, Q34); late is not an option.

02Bank of England · Oct 22

Bank of England proposes 2026/27 supervision fees for recognised payment systems

Open consultation, UK. Published 22 September 2026; closes 22 October 2026 (time not stated). Responses are requested by that date.

The Bank of England consults on its fees regime for supervising recognised payment systems and specified service providers for 2026/27. I did not review the fee levels in detail, so treat the cost impact as unchecked. Relevance to a payment institution is likely indirect, through scheme or infrastructure operators that pass costs on.

How to respond: email [email protected]. The Bank asks respondents to say whether they agree to their name, or their organisation's name, being published in its feedback response. Responses may be disclosed under the Freedom of Information Act 2000 or data protection law, and respondents should flag which parts they regard as confidential.

For a mid-size A2A payment institution: check whether your payment systems or scheme operators are in scope; if so, raise any pass-through cost effects, otherwise treat this as low priority.

03FRC · Nov 26

FRC opens consultation on the audit standard for payment firms' safeguarding

Newly opened, UK. Published 30 September 2026; the Financial Reporting Council seeks views by Thursday 26 November 2026 (time not stated). Status on the page: open.

The FRC proposes a new Appendix 13 to the CASS Assurance Standard, 'Safeguarding Assurance for Payment and E-Money Institutions', giving auditors a framework for the safeguarding audits the FCA introduced in PS25/12. It would replace the FRC's interim guidance of March 2026. The FRC says the appendix does not create the audit requirement, widen which firms are in scope, or add a new regulatory obligation.

How to respond: the invitation to comment PDF and an exposure draft are on the FRC page; I did not confirm the submission address or confidentiality terms, so check the invitation to comment.

For a mid-size A2A payment institution: you will be audited under this appendix, so review the exposure draft now with your safeguarding auditor and flag evidence burdens and timing.

Watch for the 6 October HM Treasury close and the 22 October Bank of England deadline. EU: I found no open EBA or European Commission payments consultation; secondhand commentary (Transaction Intelligence, 1 Sep 2026) says PSD3 and the PSR carry an indicative Parliament plenary date of 14 December 2026, which is a legislative step, not a consultation. The FCA Regulatory Initiatives Grid (May 2026) returned a 403 and could not be read, so forthcoming FCA items are unchecked. The ECB's Appia and the Bank of England's retail payments infrastructure consultation closed earlier (11 September), outside this window.

Coverage: Sep 28 – Oct 5, 2026 (plus open items closing by Nov 4, 2026)

Researched with GREP. Every story links to its sources.

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