A new regulatory statement on pricing
On 20 January 2026, the Financial Conduct Authority and the Payment Systems Regulator published a joint statement on open banking pricing models that focuses squarely on the UK Payments Initiative’s (UKPI) commercial VRP pricing proposal.⁴
Crucially, regulators made clear they will not, at this stage, prioritise an investigation under the Competition Act 1998 into the centralised “access fee” pricing model being developed by UKPI for Phase 1 (Wave 1) cVRP use cases.⁴ The Competition and Markets Authority has confirmed that it aligns with this position based on current information.⁴
This is an interim enforcement stance: it applies until the anticipated government legislative framework for long-term open banking pricing is in place (expected by the end of 2026), or until July 2027, whichever is sooner.⁴ During this period regulators will continue to:
- monitor market developments,
- review pricing methodologies, and
- expect UKPI to finalise and share governance documentation.⁴
All three authorities - FCA, PSR and CMA - may review their prioritisation approach if new information emerges, or if the legislative framework is delayed.⁴
Why pricing clarity matters for the open banking ecosystem
The context: how cVRP pricing differs from traditional API access
Open banking’s early phase was largely defined by regulatory API mandates. Payment Initiation Services (PIS) and Account Information Services (AIS) were offered under a consent and access model where banks exposed APIs under CMA and PSD2/PSR obligations. Commonsense reciprocity and negotiated commercial terms filled the gaps.
cVRP introduces a formalised recurring payment model where the infrastructure and scheme must be clearly priced if it is to scale sustainably. The UKPI approach - involving a centralised “access fee” that all participants agree to - is a departure from bespoke bilateral pricing and a step towards industry-wide standardisation.⁴
Without regulatory clarity on how competition law applies to these arrangements, firms could be deterred from joining or investing in the scheme, slowing its development and adoption.
What the statement means for enterprise buyers
A reduction in regulatory uncertainty
By clarifying that they will not pursue a Competition Act investigation at this stage, the FCA/PSR signal that UKPI’s commercial pricing model is not prima facie anti-competitive under current conditions.⁴ For buyers considering cVRP infrastructure, this:
- reduces legal uncertainty,
- strengthens confidence in scheme pricing stability, and
- supports investment decisions that lean on predictable cost models.
However, the statement is not a permanent endorsement. The non-prioritisation position holds only until the legislative framework arrives or July 2027, so contracts and roadmaps should anticipate a potential evolution in pricing rules.
A bridge to the future regulatory framework
The government’s planned legislative framework - likely to come into force by the end of 2026 - is expected to give the FCA new powers to set open banking rules, including pricing arrangements.⁴ Industry participants should treat the current regime as an interim state designed to facilitate early commercial rollout, not the final destination.
This is consistent with the FCA’s broader strategy to embed lessons from Phase 1 cVRP rollout into the long-term framework that will regulate open banking and related payment services going forward.¹³
Asima’s view: infrastructure buyers need pricing stability and operational clarity
For infrastructure buyers - particularly larger retailers, platforms and fintechs evaluating cVRP suppliers - this statement has three practical implications:
1. Pricing models should be predictable and aligned to scheme governance
Solutions should adopt pricing that mirrors the UKPI model’s principles:
- clear governance on how fees are set and overseen,
- independence of pricing committees from participant influence,
- safeguards against competitive distortion,
- and transparent processes for adjustment and reporting.⁴
These principles help ensure that pricing risk does not become a project risk.
2. Contracts should incorporate regulatory evolution pathways
Given the interim nature of the non-prioritisation stance, procurement teams should include provisions that:
- recognise the legislative framework’s expected introduction,
- allow for compliance with new pricing rules, and
- mitigate cost volatility if regulatory guidance changes.
Treating pricing as a dynamic input, rather than a fixed contract element, will reduce rework later.
3. Focus on operational clarity as well as price
Pricing clarity matters, but it sits beside deeper questions about:
- mandate lifecycle management,
- event and error telemetry,
- dispute handling,
- settlement certainty.
Infrastructure decisions should weigh total cost of ownership and operational resilience, not just headline fees.
Looking ahead: what comes next
The UKPI governance documents, once finalised and shared with regulators, will provide a clearer picture of pricing mechanics and oversight safeguards. Providers and buyers alike should be ready to absorb those details as they emerge.
Meanwhile, the legislative framework expected in 2026 will likely codify broader pricing oversight powers, anchoring pricing models in statute rather than guidance and prioritisation stances.
For anyone building or buying cVRP infrastructure, the message is clear:
Regulatory certainty is increasing, but it is not complete.
Plan for change, rather than assume stasis.
¹ Financial Conduct Authority & Payment Systems Regulator. Regulators give clarity in relation to open banking pricing models. 20 January 2026. Link
² Payment Systems Regulator & Financial Conduct Authority. Joint prioritisation statement on UKPI commercial VRP pricing model. 20 January 2026. Link
³ FCA. Open banking: a year of progress. 16 December 2025. Link
⁴ Open Banking Limited. Commercial model consultation insights. 2025. Link
