FCA and PSR Provide Regulatory Clarity on Open Banking Pricing for cVRPs

The Financial Conduct Authority (FCA) and the Payment Systems Regulator (PSR) have issued a joint statement providing important regulatory clarity on open banking pricing models, specifically in relation to commercial Variable Recurring Payments (cVRPs). The statement confirms that, at this stage, the regulators will not prioritise a Competition Act 1998. Investigation into the centralised access fee pricing model being developed by the UK Payments Initiative for cVRPs.

Commercial Variable Recurring Payments are an emerging open banking capability that allow consumers to grant trusted third parties secure, recurring access to manage payments on their behalf. The technology has the potential to give consumers greater control over their finances, while offering businesses a lower-cost and more flexible alternative to existing payment mechanisms.

Following engagement with the funders of the UK Payments Initiative, the FCA and the PSR moved quickly to clarify their enforcement position on the proposed commercial model. In line with competition law concurrency arrangements, they also consulted with the Competition and Markets Authority (CMA) before issuing a formal non-prioritisation statement. This approach is intended to provide UKPI with sufficient certainty to continue developing its cVRP proposition without delay, including use cases covering regulated financial services, utilities and public sector payments.

The regulators have positioned this decision as supportive of their broader strategy to make cVRPs a practical reality in the UK payments landscape. By reducing regulatory uncertainty at this early stage, the FCA and PSR aim to encourage innovation that delivers more control for consumers and lower processing costs for businesses.

On 15 January 2026, the FCA and PSR wrote to the CMA to set out their position on competition enforcement prioritisation. The following day, 16 January 2026, the CMA confirmed that, based on the information available, it did not intend to take a different approach. The CMA emphasised the importance of ensuring that businesses are not discouraged from collaborating in ways that could benefit consumers or the wider economy due to uncertainty around the application of competition law.

The non-prioritisation position is explicitly temporary and is intended to act as a bridge to a longer-term legislative framework. The government’s anticipated framework for open banking and payments innovation is expected by the end of 2026. The statement will apply until that framework is implemented or until July 2027, whichever comes first.

During this interim period, the FCA and PSR will continue to monitor market developments, review any changes to the proposed pricing methodology, and expect UKPI to submit its finalised governance documentation. All three competition authorities, the FCA, PSR and CMA, have reserved the right to revisit their prioritisation approach if new information emerges or if the anticipated legislative framework is not delivered by July 2027.

For firms operating in payments, open banking and adjacent financial services, the statement provides short-term regulatory certainty while signalling that pricing models and governance arrangements will remain under close supervisory and competition scrutiny as the market evolves.

Read the joint statement here.