Author: James Borley, Director of Payment Services
On 26 February 2026, the Payments Vision Delivery Committee published the UK’s first Payments Forward Plan; a three-year sequenced roadmap for payments policy aimed at clarifying, prioritising and coordinating the raft of initiatives that have emerged out of the government’s National Payments Vision (NPV).
This is not a policy consultation nor an exhaustive technical rulebook; it’s a planning tool. Its explicit purpose is to help the public and private sectors plan with certainty, align activity, reduce duplication and give industry a clearer picture of what’s coming, when and how it contributes to the NPV.
In unpacking the Plan, it’s worth being clear: the piece has two distinct but related functions. First, to give industry a sense of sequencing for delivery so firms can resource and schedule rather than react. Second, to signal a higher degree of coordination across authorities than historically has been visible in UK payments policy.
What is the Payments Forward Plan?
The Payments Forward Plan, eight pages of scheduled work, was produced by a formal committee with representatives from:
- HM Treasury
- The Bank of England
- The Financial Conduct Authority (FCA)
- The Payment Systems Regulator (PSR)
This cross-authority group brings together the public sector initiatives that will shape UK payments policy over the next three years in retail payments, wholesale payments and digital assets.
Far from being a static snapshot, the Forward Plan explicitly codifies sequencing, showing how individual initiatives relate to one another and to the broader strategic objectives of the NPV. It is not a substitute for regulatory or legislative texts, but it makes visible what regulators intend to do, and when they intend to do it.
The Forward Plan builds directly on the work initiated by the Future of Payments Review and the subsequent NPV. The Vision set out a long-term ambition for the UK to have a trusted, competitive, innovative and resilient payments ecosystem built on next-generation technology and user choice.
However, stakeholders have repeatedly asked for clearer sequencing and a consolidated line of sight on the regulatory pipeline, namely, which policies are expected to affect the industry and when. That was the rationale behind creating the Payments Vision Delivery Committee, and the Forward Plan is its first major public output.
Structure and Content: A Sequenced Pipeline
The Forward Plan organises initiatives into logical timebands over a three-year horizon, not unlike a rolling programme for infrastructure reform. It covers several clusters:
- Retail Payments Modernisation
This area covers multiple interconnected programmes spanning open banking, new payment rails and broader ecosystem development:
- Open Banking and cVRPs: The Plan references timing for commercial Variable Recurring Payments (cVRPs) under the UK Payments Initiative.
- Retail infrastructure design and delivery: Continued development of modernised retail rails, including short-term enhancements to existing systems like Faster Payments and BACS.
- Stablecoins and Digital Assets: Sequencing for the policy framework on stablecoins remains in the pipeline, with consultations and blueprint work stretching through 2026.
Crucially, this segment emphasises making actual payments work on next- payment infrastructure, not merely policy development.
- Wholesale PaymentsandInnovation
The Plan recognises the Bank of England’s wholesale experiments programme and signals ongoing exploration of cutting-edge infrastructure, including how tokenised assets and settlement innovation might feature in the future.
While some of these experiments are technical in nature, their sequencing speaks to the UK’s ambition to bridge domestic and cross-border payments capabilities with innovation rather than incremental fixes.
- Regulatory Framework Reforms
The sequenced pipeline includes several major framework initiatives that will shape the regulatory landscape for years to come:
- Review of assimilated payments law: This includes the Payment Services Regulations 2017 and the Electronic Money Regulations 2011. Consultations and engagement are expected through 2026, with subsequent statutory instruments anticipated.
- Potential consolidation of the PSR into the FCA: The Plan signals continued work during 2026/27 regarding the proposed consolidation of the PSR into the FCA.
- Systemic fee cap and Financial Ombudsman Service reforms: Consultations are anticipated in 2026 regarding fee cap arrangements and potential reforms affecting complaint handling and redress frameworks. Firms should consider the interaction with DISP requirements in the FCA Handbook.
Collectively, these signal potential structural changes in the regulatory architecture, that will likely reshape how firms engage with and comply under UK payments regulation in the long run.
- Consumer and System Safeguards
The Plan also lays out timings for initiatives focused on protecting users and enhancing trust in the system, where the operational risk profile and compliance obligations for firms are acute:
- Anti-money laundering and fraud initiatives planned for delivery over the course of 2026.
- Authorised Push Payment (APP) Fraud strategy and Measurement Frameworks feeding into the “Access to Cash” evaluation framework.
- FCA consumer protection workstreams on treatment of vulnerable consumers and enforcement outcomes stretching into 2027.
- International Payments
The Plan acknowledges that the UK’s open, cross-border payments ambitions must align with global interoperability and competitiveness and includes commitments to support global efforts to make cross-border payments faster, cheaper and more transparent.
Why It Matters
One of the biggest practical complaints from industry over the past few years has been multiple overlapping consultations and policy favourites from multiple authorities with no clear sense of sequencing. The Plan directly addresses that complaint by offering a line of sight across initiatives.
For firms, this enhances operational planning, prioritisation of projects and more predictable resource allocation. For regulators, it means activities are more likely to interact with one another. Before the Forward Plan, much of the UK’s payments policy felt siloed e.g. open banking in one bucket, wholesale innovation in another, and legal reform in another.
By clarifying indicative timelines for key innovations, such as cVRPs and infrastructure modernisation, the Plan could unlock faster adoption of next-generation payment capabilities. It also creates a more predictable environment for investment decisions, which industry bodies have long argued is critical for UK competitiveness.
However, as some industry commentators have already noted, the success of this roadmap will depend on regulators moving from sequencing intentions to delivery action, especially in areas where timing really matters (e.g., open banking extension to e-commerce).
Sequencing signals also help firms anticipate compliance risk peaks and troughs. For example, knowing when major statutory instruments are planned to be laid or when major consultations will conclude helps payments firms embed compliance efforts into their delivery pipelines.
Challenges and Limitations
No roadmap guarantees successful execution, and the Forward Plan raises important practical considerations:
Timing Ambiguity – The use of broad windows (e.g., “Q2-Q4 2026”) reflects the reality that many policy processes cannot be pinned down precisely. For firms accustomed to hard deadlines, this inherently limits some planning value.
Regulatory Coordination – While the Plan tries to knit together multiple authorities’ agendas, real organisational incentives still differ. Aligning these in practice could be a challenging, multi-year endeavour.
Industry Participation – Sequencing does not guarantee engagement effectiveness. Industry reactions to the Plan will depend on meaningful stakeholder input throughout the consultation and implementation process.
Conclusion: A Milestone, Not a Destination
The Payments Forward Plan is, for the UK payments ecosystem, a milestone in maturing policy delivery. Built on the backbone of the National Payments Vision, it offers firms and regulators a shared roadmap for the next three years. It is as much a statement of coordination as it is a sequenced pipeline of initiatives.
If executed with discipline, this Plan could finally give the payments sector the much-desired predictability, clarity, and coherence that has long been lacking. If not, it risks becoming another well-intentioned document on an ever-growing regulatory bookshelf.
How Complyport Can Help
Complyport supports payment institutions, e-money firms and cryptoasset businesses in managing regulatory change, including:
- FCA authorisation and variation of permission applications;
- Ongoing compliance advisory and regulatory health checks;
- Consumer Duty implementation and governance reviews;
- AML and financial crime framework enhancement;
- Safeguarding audits and prudential compliance assessments; and
- Regulatory change management and impact analysis.
If your firm would like to discuss how the Payments Forward Plan may affect your regulatory strategy, contact Complyport to arrange a meeting with one of our specialists.
Ask ViCA, your Virtual Compliance Assistant. Claim your complimentary 20 queries today! Register here: https://vica.chat
