On 15 October 2026, the Payment Systems Regulator (PSR) published a consultation paper (CP) on the regulatory framework for access to payment systems.
Background
HM Treasury (HMT) plans to repeal the payment system access regime in the Payment Services Regulations 2017 (PSRs 2017), as set out in its response to the consultation ‘A Streamlined Approach to Payment Systems Regulation’. The PSR makes clear that this CP assumes that change goes ahead as planned and is being issued to ensure continued coverage for the access regime upon the transfer of the PSR’s responsibilities to the Financial Conduct Authority.
Summary
The PSR is proposing the following changes in light of HMT’s proposals, in particular:
- Changes to the Regulatory Framework: To maintain continuity following HMT’s proposed changes, the PSR proposes revising General Direction 2 (GD2) so that it becomes the primary regulatory instrument governing both direct and indirect access, while revoking General Direction 3 (GD3), which would become redundant. The revised GD2 would largely replicate existing requirements currently spread across the PSRs 2017, GD2 and GD3, creating a single, streamlined framework. The PSR sets out that it considers that underlying policy approach would remain unchanged, with continued emphasis on access arrangements being proportionate, objective and non-discriminatory (POND). The PSR also emphasises that it is not undertaking a wider review of access policy, reconsidering the POND criteria, or introducing new or expanded access obligations.
- Revisions to GD2: GD2 would become the single reference point for access regulation across all regulated payment systems. Operators would continue to be subject to requirements relating to access criteria, publication, notification and annual reporting. Indirect access providers would continue to be required to provide access on a POND basis and to give reasons when access is refused. A key proposal is the introduction of a single test for both direct and indirect access. The new test would require access requirements to be proportionate, objective and non-discriminatory, and not restrict access more than necessary to address specific risks or protect financial and operational stability. The PSR considers this a simplification rather than a substantive policy change.
- Procedural Requirements: The PSR proposes extending the requirement to publish access requirements to all regulated payment system operators, promoting greater transparency and consistency. However, it does not propose extending notification or annual reporting obligations to indirect access providers.
- Updated guidance: The updated guidance would consolidate existing material into a single framework, while retaining its substance. Minor amendments include removing provisions on access to bank accounts, eliminating the pre-application dispute stage, and revising indicative timelines for access applications to better reflect current practice.
Next Steps
The PSR has asked for comments on this CP by 10 December 2026.