Business leaders in the UK whose organisations depend on payments infrastructure – platforms, merchants, financial institutions, or technology providers may find the Payments Association’s Payments Manifesto 2026 an absorbing read. Its central claim is direct: payments are now a limiting factor for growth, and the UK risks losing ground unless regulatory, and commercial decisions align soon.
The document is drawn from input from c. 150 member organisations in banking, fintech, payments, and infrastructure. It aligns with stated UK government priorities, including the National Payments Vision and recent Mansion House speeches. The manifesto points to delays, fragmented accountability, or regulatory choices that conflict with market freedoms.
Regulation is a constraint
The manifesto’s treatment of payments infrastructure is its most concrete section. The formation of the Retail Payments Infrastructure Board and a proposed industry-led Delivery Company is framed as progress, but the document stresses that governance as of itself will not deliver outcomes.
The industry already has real-time payments systems, AI-based fraud tools, and modern messaging standards. The problem identified is execution under regulatory constraint. Infrastructure change requires rapid decision-making and a tolerance for risk. The paper argues current approval processes and oversight models slow delivery and weaken accountability.
The request for “strategic guardrails [not] prescriptive rules” reflects operational experience. Without shorter approval cycles and clearer ownership, infrastructure upgrades will lag behind comparable markets, regardless of funding.
Fraud has moved
Financial crime receives sustained attention, reflecting its scale and cost. The manifesto cites reimbursement data showing that around 87% of authorised push payment fraud losses have been repaid since late 2024, and overall fraud volumes remain stable.
For CFOs, this implies a redistribution of cost not a reduction. Reimbursement has moved losses onto payment service providers without addressing the incentives for fraud, particularly in online platforms and telecommunications channels. The manifesto’s proposals is one of shared liability models, mandatory data sharing, and a Digital Payments Fraud Centre. Here the Payments Association draws on international precedents.
It argues against reimbursement without accountability. In its absence, fraud remains economically viable.
Stablecoins and regulatory misalignment
The manifesto is most direct on digital currencies, especially stablecoins. It highlights a gap between government ambition and regulatory design. While ministers may promote tokenisation and digital assets, the Bank of England and the FCA are described as moving with caution that may deter the markets.
The issue is framed as more practical than philosophical, arguing complex compliance requirements and high capital thresholds push issuers to operate outside the UK. This risks the loss of liquidity and talent.
There is focus on use cases in cross-border settlements, treasury management, payroll, and SME finance. Risks are acknowledged, but the cost of delay is greater than the risk of regulation, the paper says.
Open Banking has levelled-out
From a growth and customer perspective, the manifesto’s assessment of open banking is that adoption has stalled due to compliance replacing commercial incentive. Variable recurring payments are presented as evidence that uptake follows workable business models.
It calls for clearer consumer language and consistent dispute resolution to reflect the market’s opinions. The manifesto does not argue for reduced regulation, but for regulation that allows monetisation and competition.
The implication for firms designing payment journeys is that open banking will not scale unless can compete on cost and user experience.
Regulation as an input to growth
In many of its sections, the manifesto returns to a theme of the gap between pro-growth policy statements and ensuing regulation. Firms to face long authorisation timelines, inconsistent supervision, and suffer from the need to duplicate their reporting efforts.
This critique is backed by proposals that include performance benchmarks for regulators, internal case-tracking systems, and risk segmentation between firms.
Conclusion
The Payments Manifesto 2026 is an advocacy thought-piece, posing as an objective survey. Its arguments are strongest where it presents existing results which demonstrate slow infrastructure delivery, the rising cost of fraud, digital assets being allowed free movement, and the current under use of Open Banking.
Payments strategy can’t sit in Compliance or IT business functions, the paper states. It positions payments policies next to infrastructure choices, fraud allocation, regulatory positioning, and customer experience in importance.
(Image source: “Point of Sale” by Consumerist Dot Com is licensed under CC BY 2.0.)
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