Two regulators are live on UK payments right now — here’s what that split actually asks of you before the end of the year.
The signal, briefly The PSR is being folded into the FCA. Treasury confirmed the direction in April, the Bill enabling it is now before the Lords, and the transfer is expected to complete around end-2026. In the meantime the FCA is already acting on payments-competition powers that used to sit with the PSR alone — which means for the rest of this year, you’ve got two active regulators with overlapping mandates.
What this changes operationally
Nothing changes today in your licensing, your safeguarding obligations, or your APP fraud liability. Those hold as they are. What’s actually live is contract risk and escalation clarity. If any of your payments or lending agreements name the PSR specifically — rather than “the applicable regulator” — that clause is sitting on shifting ground. Cash and credit categories aren’t touched. Contracts and provider relationships are, if you’ve got legacy language in there. Hiring and customer-facing decisions: unaffected, don’t let this bleed into areas it has no business touching.
Founder actions, ordered by urgency
- This week — finance lead pulls your payments and lending contracts. Search for any explicit PSR references (not generic “regulator” language). Flag them; don’t renegotiate yet, just know where they are. Fifteen minutes, one document search.
- Next fortnight — founder or finance lead asks your provider directly. One email to your payment processor, acquiring bank, or lender: “how are you preparing for the PSR-FCA transfer?” Their answer — specific and detailed, or vague and dismissive — tells you how seriously they’re tracking their own regulatory exposure, which tells you something about them as a counterparty.
- This quarter — set a standing calendar check, not a news habit. Ops lead or founder logs a quarterly reminder to check the Bill’s parliamentary stage. The decision criterion for acting further: once the Bill receives Royal Assent and a commencement date is set, that’s when contract language actually needs rewriting — not before.
What not to do
Don’t rush to renegotiate contracts today. The Bill hasn’t passed, the transfer date isn’t fixed, and rewriting agreements against a moving regulatory target wastes legal spend on terms that may shift again before commencement. And don’t treat this as a reason to switch payment providers — a provider that can’t yet explain their PSR-transfer prep isn’t necessarily a bad provider; almost none of the market has this fully mapped yet. React to what’s confirmed, not to what’s still in motion.
Sign-off Next week we turn from who’s watching your payments to who’s lending into your business — the SME lending signal is picking up, and it’s worth your Monday attention.
