Why card fees are back in focus
Over the past year, the Payment Systems Regulator (PSR) has continued to apply pressure on card scheme fees and governance, particularly around transparency, predictability and the ability of merchants to understand what they are paying and why.¹²
While individual announcements have focused on specific fee categories or governance remedies, the underlying concern is consistent: buyers of payment services often have limited visibility or leverage over pricing decisions made upstream.
This is not a new problem, but it is becoming more visible as costs rise and margins tighten.
The deeper issue is governance, not cards
It would be a mistake to read recent PSR activity as “anti-card”. Cards remain an essential part of the payments mix, and the PSR has been explicit that its role is not to pick winners.
Instead, the regulator’s actions point to a broader issue: how pricing power, rule-setting and accountability are distributed across a payment rail.
In the card ecosystem:
- pricing decisions are typically made by schemes,
- changes can cascade quickly through acquirers to merchants,
- and contractual leverage is often asymmetric.
For large merchants and platforms, this creates a structural procurement challenge: cost and rule changes may be predictable in hindsight, but rarely controllable in advance.
What the PSR is implicitly asking buyers to do
When regulators push for transparency and governance remedies, they are also nudging buyers towards more mature procurement behaviour.
That means asking questions such as:
- Who sets the rules for this rail?
- How are pricing changes governed?
- What recourse exists if outcomes deteriorate?
- How visible are disputes, failures and exceptions?
- What happens when the rail evolves?
These questions apply as much to newer account-to-account rails as they do to cards.
Open banking and cVRP are not exempt from scrutiny
It is tempting to assume that Pay by Bank or commercial variable recurring payments (cVRP) automatically avoid these issues. They do not.
Open banking introduces different economics and risk profiles, but the same procurement disciplines apply:
- pricing models need governance,
- operators need accountability,
- and buyers need clarity on how rules change over time.
The difference is that open banking is still forming its long-term structures, which gives buyers and suppliers a chance to get this right earlier.
Scheme alignment
One of the most important signals from the UK open banking ecosystem over the past year has been the move towards industry-owned, scheme-level governance for commercial payments.
The creation of the UK Payments Initiative (UKPI) to deliver commercial VRPs is a concrete example of this shift.³
Rather than relying on bilateral arrangements, UKPI is designed to:
- operate under a multilateral agreement,
- provide clearer governance over pricing and participation,
- and offer regulators a structure they can reason about.
As a founding member of UKPI, Asima sees this as a necessary step if account-to-account payments are to scale sustainably.
Procurement: what buyers should compare
When comparing card rails with open banking or cVRP, buyers should move beyond unit cost comparisons and consider:
1. Pricing governance
How are fees set, reviewed and challenged?
Is there an operator or scheme body with defined responsibilities?
2. Rule-setting and change control
Who decides when rules change, and how much notice is given?
Is there a formal process or unilateral discretion?
3. Observability and evidence
Can you see what is happening across transactions, disputes and failures?
Can you evidence outcomes to regulators and auditors?
4. Liability and dispute handling
Where does liability sit when things go wrong?
Are dispute flows defined, or improvised?
5. Long-term adaptability
How likely is this rail to evolve in ways that force re-engineering?
Are you aligned with where regulators are heading?
These questions are as relevant to cVRP procurement as they are to card acquiring.
The Asima view: rails are long-term decisions
The PSR’s focus on card fees should be read as a reminder rather than a warning.
Payment rails are infrastructure choices, not just commercial contracts. Once embedded, they shape:
- cost structures;
- operational complexity;
- and regulatory exposure for years.
Open banking and cVRP offer real advantages, particularly around consent, authentication and transparency. But those advantages only materialise if governance is taken seriously from the start.
For buyers, the lesson is simple: procure rails the way regulators expect them to behave, not just the way they behave today.
¹ Payment Systems Regulator. PSR update on card scheme and processing fees. Link
² Payment Systems Regulator. Market review into card scheme and processing fees. Link
³ Financial Conduct Authority. Open banking: a year of progress. Link
