PSR Annual Plan 2026/27 - Card Fees, APP Fraud & Open Banking Reform
The Payment Systems Regulator has published its 2026/27 Annual Plan, setting out a focused work programme centred on three priorities: tackling excessive card fees (domestic and cross-border), maintaining and reviewing APP fraud reimbursement protections, and supporting the delivery of the National Payments Vision alongside the Bank of England, FCA, and HM Treasury.
Context:
Released against the backdrop of the government's consultation on merging the PSR into the FCA, the 2026/27 Annual Plan positions the PSR as providing 'continuity, clarity and confidence' during a transitional period. Managing Director David Geale confirmed the PSR's intention to finalise card scheme and processing fee remedies, publish an independent review of the first year of mandatory APP scam reimbursement, and drive the next phase of open banking.
On card fees, the PSR is pressing ahead with implementing directions on Information Transparency and Complexity (ITC) and Pricing Governance following its market review final report. A third remedy, Regulatory Financial Reporting is expected to be consulted on in spring 2026. Cross-border interchange fees (between UK and EEA) are also receiving attention, with remedies in development. A final decision on all scheme remedies is expected by end of June 2026.
On APP fraud, the first mandatory reimbursement rules (which came into force in October 2024) are being independently reviewed. The PSR has shared real-time fraud data with the FCA, enabling firms with high fraud rates to be identified and engaged. The open banking workstream focuses on the transition of regulatory oversight to the FCA and the development of variable recurring payments (VRPs) for wider commercial use cases.
Rules and Guidelines:
Specific directions on ITC and Pricing Governance are being finalised; Mastercard and Visa must provide acquirers with clear, actionable pricing information
A third remedy (Regulatory Financial Reporting) will be consulted on, requiring schemes to report financial performance data to the PSR
Cross-border interchange fee remedies are in development, watch for consultation in 2026/27
APP fraud: firms must continue meeting mandatory reimbursement obligations under existing PSR rules; the independent review will assess adequacy and may prompt further changes
PSR consolidation into FCA expected to proceed, this will affect the legislative basis for PSR directions but not the underlying substantive policy
Open Banking: the Future Entity framework will be developed; commercial VRP phase 1 is being rolled out
Businesses Affected:
Card scheme operators (Mastercard, Visa) are directly subject to ITC and Pricing Governance directions
Acquirers and payment processors who will benefit from clearer, standardised fee information from schemes
Merchants and retailers who pay card fees are expected to benefit from competitive pricing improvements over time
Banks and payment service providers are subject to APP fraud reimbursement obligations
Open banking players: TPPs, AISPs, PISPs, and banks building VRP infrastructure
Firms preparing for the PSR's absorption into the FCA and the resulting structural changes to payments regulation
Next Steps:
Card schemes and acquirers: engage with the ITC and Pricing Governance consultation directions and prepare for compliance before the June 2026 final decision
All payment service providers: check compliance with existing APP fraud reimbursement rules and ensure fraud prevention frameworks are robust ahead of the independent review
Monitor the spring 2026 consultation on Regulatory Financial Reporting (third card scheme remedy) and respond
Open banking participants: engage with the FCA's new Payments department on VRP commercial model development and Future Entity design
Track the PSR-into-FCA merger progress and monitor secondary legislation for changes to the PSR's statutory basis and ensure compliance frameworks remain current
Prepare for cross-border interchange fee remedies consultation and review pricing strategies for UK-EEA transactions
PSR, Annual Plan
