The Payments Newsletter including Digital Assets & Blockchain, October 2025

The Hogan Lovells Payments Conference is taking place on Thursday 20 November 2025. The payments industry continues to develop and evolve at pace. Our conference this year will explore this growth in the context of rapid technological innovation and increasing geopolitical and economic uncertainty.

Discussions will investigate topics currently affecting the sector, and on the horizon, such as the potentially transformative impact of AI, the rise of digital currencies and prospect of a decentralised economy, the fight against financial crime and the continued development of new payment methods. Members of our global team will also share their thoughts on how the sector, and the regulatory landscape it operates in, are changing in their local jurisdictions.

To take a look at the current agenda and register your interest in attending, please click here.

The European Union's Financial Data Access Regulation (FiDA) is set to reshape the financial services landscape, expanding data sharing far beyond the boundaries established by PSD2. Our new FiDA Impact Report provides a clear, practical overview of what's changing, who will be affected, and why it matters. Whether you're a bank, insurer, investment firm, pension provider, FinTech, or advisor, this report is your essential guide to understanding the opportunities and challenges ahead as open finance becomes a reality across the EU and UK. Discover how FiDA will drive innovation, empower customers, and create new business models—while also raising important questions about compliance, security, and competition. For more on the background and why you should be reading the report, see this Our Thinking article.

On 25 September 2025, we gathered financial institutions, policymakers, innovators and market players, and Hogan Lovells Partners to our London office (in-person and virtually) for our 6th annual summit on digital assets, held in partnership with Global Digital Finance. This year, the theme of our summit is Winds of Change, focusing on global policy and regulatory shifts in approaches towards digital assets in financial services.

With over 300 attendees (155 in person, 165 virtual) and 19 expert speakers, the Digital Assets Summit delivered a powerful day of insights and global perspectives on the future of finance. For a summary of the key takeaways from the summit, take a look at this Our Thinking article.

United Kingdom: FCA publishes findings from romance fraud multi-firm review

On 17 October 2025, the FCA published the key findings from its multi-firm review of how firms detect and prevent romance fraud, and the measures they take to protect their customers against it.

The review involved a sample of 6 firms, including retail banks and payment firms - some well-established and others newer market entrants. The FCA assessed 60 confirmed romance fraud cases, where losses ranged from £100 to £428,249.

In its findings, the FCA highlights areas where it thinks more could be done by firms themselves to prevent and detect romance fraud and to protect victims, dividing its findings into 5 main areas of focus:

• Detection and monitoring;
• Internal investigative approaches and staff capabilities;
• Customer engagement and support;
• Treatment of customers in vulnerable circumstances; and
• Education and awareness.

The FCA highlights the ‘critical importance’ of both effective transaction monitoring systems and skilled, well-trained staff. This latter area can be particularly key in helping to break the fraudster’s hold over their victim through the ability to spot red flags and critically probe customer explanations.

The FCA expects all firms to consider the findings and assess whether their own systems, controls and customer engagement practices are sufficient to prevent and respond to romance fraud. It also emphasises that the findings should inform firms’ broader fraud strategies.

Take a look at this Our Thinking article for more on this development.

United Kingdom: PSR publishes update on APP fraud mandatory reimbursement scheme

On 8 October 2025, the Payment Systems Regulator (PSR) published an update on its authorised push payment (APP) fraud mandatory reimbursement scheme, a year on from it coming into force (7 October 2024). Key points include the following:

• An independent evaluation of the scheme by Frontier Economics is under way. This will assess the scheme’s effectiveness and identify improvements. Findings are due in Q2 2026. The PSR will consider whether any aspects of the scheme should be reviewed when the report is published.
• In the first nine months following introduction of the scheme:
  • £112 million was reimbursed to victims;
  • 97% of claims were resolved in 35 days and 84% of claims were resolved within five business days; and
  • Claim volumes are down – the PSR comments that this shows firms are ‘stepping up and stopping fraud in response to the requirements’.
• Awareness of the scheme remains low: 71% of consumers surveyed were unaware; 49% of victims didn’t attempt reimbursement.

Colombia: Bre-B instant payment system launches nationwide to expand digital access

On 6 October 2025, Colombia officially launched Bre-B, its national instant payment network, marking the start of full-scale operations following a brief pilot phase. The launch had previously been delayed from its original September timeline (see more in our September edition).

Modelled after Brazil’s Pix, Bre-B offers 24/7 availability, immediate settlement, and interoperability across financial institutions. Developed by Colombia’s central bank, the system connects existing payment services and enables international merchants to accept Bre-B payments from the first day of its rollout.

More than 30 million Colombians – around 76% of the adult population – have already registered for Bre-B, reflecting strong demand for digital payments in a country where only 18% have access to credit cards. The system currently supports person-to-person and consumer-to-merchant transactions, with plans to expand to government payments and bulk transfers.

Global: FSB publishes consolidated progress report on G20 roadmap for enhancing cross-border payments

On 9 October 2025, the Financial Stability Board (FSB) published its consolidated progress report on the G20 roadmap for enhancing cross-border payments, warning that global regulators are unlikely to meet the initiative’s 2027 targets. Launched in 2021, the roadmap aims to make international payments faster, cheaper, more transparent, and more accessible – setting goals such as reducing average retail payment costs to below 1% and ensuring most transactions are credited within an hour.

While the FSB noted progress in building infrastructure and policy frameworks, its latest key performance indicators show only marginal improvements since 2023. Wholesale and remittance transaction speeds have also improved, but costs remain high and transparency continues to lag. In regions like sub-Saharan Africa, remittance fees still average around 4%, well above the G20’s target.

The FSB attributed the slow progress to the complexity of coordinating upgrades across jurisdictions and the scale of infrastructure reform required. It acknowledged that the 2027 goals are unlikely to be met, leaving G20 policymakers to consider extending the timeline or revising targets.

Improving the foundational infrastructure – such as enabling 24/7 operations and adopting standardised messaging protocols – remains a priority. The report also notes that while digital assets like stablecoins are being explored, their role in solving cross-border inefficiencies is still uncertain.

United Kingdom: Bank of England publishes policy statement on expanding mandatory ISO 20022 enhanced data in CHAPS

On 22 September 2025, the Bank of England (BoE) published a policy statement on expanding mandatory ISO 20022 enhanced data in CHAPS from 2027.

The BoE has updated its position on the two proposed policy positions from its April 2024 consultation in light of feedback:

• Purpose Codes: From November 2027, the BoE will expand mandatory requirements for Purpose Codes to all CHAPS payments. These requirements will continue to be mandated through the CHAPS rulebook for payment initiation channels within direct participants' (DPs) control. The BoE is also enhancing the way it engages with the industry to develop guidance for consistent use of Purpose Codes. This will include guidance on the selection of appropriate Purpose Codes and other enhanced data, as well as on implementing best practice on incorporating enhanced data within CHAPS payment journeys.
• Payment initiation channels outside CHAPS DPs' control: The BoE will not expand mandatory enhanced data requirements to payment initiation channels outside CHAPS DPs' control in 2027. However, it expects that more volume will move into the control of CHAPS DPs as more payment systems migrate to ISO 20022.

The BoE did not consult specifically on any changes to its legal entity identifier (LEI) policy, but it received specific feedback on its approach to the inclusion of LEIs within ISO 20022 payment messages. In response, it has taken a couple of specific steps to enhance the experience of stakeholders in conjunction with other organisations, which are set out in the Annex to the policy statement.

United Kingdom: PSR publishes decision and consultation on cross-border interchange fee cap

In its December 2024 final report on the market review into UK-EEA cross-border interchange fees, the Payment Systems Regulator (PSR) concluded that a price cap was the only effective remedy to mitigate the harm to merchants and their customers resulting from the post-Brexit increases in the levels of cross-border interchange fees for UK-EEA card-not-present transactions.

It launched a consultation on remedies, which closed in February 2025, in which it sought stakeholder views on a phased approach to remedies, specifically on whether to impose an initial, interim cap which would remain in place while it carried out the relevant work to determine the appropriate level for those interchange fees.

Visa and Mastercard are currently challenging the PSR via judicial review.

On 10 October 2025, the PSR published both a decision and a consultation in connection with the proposed interchange fee cap, as part of which it confirmed that it will not impose an interim cap on cross-border card-not-present transactions. The primary reason appears to be that it would not be appropriate to proceed with an interim cap whilst litigation is ongoing.

The consultation on the methodology for setting the eventual fee cap closes on 21 November 2025.

European Union: Implementing Regulation on ITS reporting of charges data for credit transfers under SEPA Regulation published in OJ

On 6 October 2025, Commission Implementing Regulation (EU) 2025/1979, containing implementing technical standards (ITS) on uniform reporting templates, instructions and methodology for reporting the level of charges for credit transfers, instant credit transfers and payment accounts, and the share of rejected transactions under Article 15(5) of the SEPA Regulation ((EU) 260/2012), was published in the Official Journal of the European Union (OJ). It entered into force on 26 October 2025.

The ITS standardise reporting from payment service providers requiring them to report to their national competent authorities:

• The level of charges for regular credit transfers and instant credit transfers with breakdowns by type of transfer (national and cross-border), type of payment service users, type of payment initiation channels and by party that is subject to the charge; and
• Charges for payment accounts, as well as the share of instant transfers, both domestic and cross-border, that were rejected due to the application of EU-wide restrictive measures.

European Union: EBA publishes report on use of white labelling in EU banking and payments sector

On 14 October 2025, the European Banking Authority (EBA) published a report and accompanying factsheet on the use of white labelling in the EU banking and payments sector.

The report defines white labelling as a business model where a financial institution (the provider) partners with another entity (the partner) to distribute financial products and services solely under the partner’s brand. The EBA finds that white labelling is widely used across credit institutions, e-money and payment institutions, non-bank lenders, and issuers of asset-referenced tokens. It identifies several regulatory challenges, including:

• Ensuring compliance with anti-money laundering (AML) and counter-terrorism financing (CFT) obligations;
• Clarifying the regulatory classification of arrangements (e.g. outsourcing, agency, or third-party reliance); and
• Guaranteeing that partners meet applicable regulatory standards.

The report also highlights consumer risks, such as lack of transparency around the roles of involved entities, increased fraud risk, and unclear product information.

While the EBA does not propose changes to EU law, it calls for greater supervisory convergence among national competent authorities (NCAs) to promote a common understanding of white labelling risks and classifications. It plans to facilitate supervisory dialogue in 2026, including case study discussions and improved consumer disclosures to clarify contracting parties and complaint channels.

European Union: EBA publishes work programme for 2026

The European Banking Authority’s (EBA) work programme for 2026, published on 1 October 2025, includes developing its work relating to the European Commission's proposed Directive on payment services and electronic money services in the internal market (PSD3), the proposed Payment Services Regulation and the proposed Regulation on a framework for financial data access (FiDA).

United Kingdom: FCA publishes research note and next steps on open banking and open finance and announces new open finance partnership and launch of open finance TechSprints

On 6 October 2025, the FCA published a research note on open banking and open finance in the UK and set out its next steps in this area.

The note sets out both the potential benefits and risks of open finance, the trends in how open banking is behind adopted and the key considerations when designing open finance. It also proposes a strategy and delivery plan for future action. Key findings are:

• Open banking is steadily advancing in the UK, following a trajectory similar to other fintech innovations.
• The UK’s experience, along with international models, offers valuable lessons to inform the development of open finance.
• Issues such as fragmented regulation, misaligned commercial incentives, and uneven consumer trust still need to be addressed.
• Clear roadmaps for both open banking and open finance can foster industry coordination and attract investment.

In terms of next steps:

• Technology and infrastructure: Through the Smart Data Accelerator, the FCA is evaluating emerging technologies (AI, blockchain, quantum computing) to guide future infrastructure and regulatory planning for open finance.
• Cross-sector and international testing: The FCA is expanding smart data use cases beyond financial services to unlock wider consumer and business benefits.
• Commercial VRP services: There is ongoing work with industry to roll out variable recurring payments, offering consumers more flexible payment options.
• Open finance roadmap: The FCA will continue stakeholder engagement and aims to publish a comprehensive open finance roadmap by March 2026.

On 13 October 2025 the FCA published a press release announcing a new partnership to accelerate the delivery of open finance and the launch of two open finance TechSprints – the Mortgages Open Finance TechSprint and the SME Finance TechSprint – that will be run between 17 November 2025 and 12 February 2026. The sprints are open for registration until 2 November.

United Kingdom: Recent FCA Consumer Duty publications

On 30 September 2025, the FCA published a webpage setting out its areas of focus for the Consumer Duty for 2025/26. It has prioritised initiatives where it can share more information on good and poor practice, and it sees the greatest need to address actual or potential harm. Its four priority areas are:

• Embedding the Consumer Duty and sharing good practice: To understand how firms are improving consumer outcomes, the FCA intends to carry out multi-firm projects to look at how the duty is being embedded across sectors.
• Vulnerability and data protection: Together with the Information Commissioner's Office (ICO), the FCA will provide further clarity to firms on the interaction between vulnerability, data sharing and data protection expectations in Q1 2026.
• Supporting firms to deliver good outcomes under the price and value outcome: This includes the FCA’s market study into premium finance.
• Sector-specific priorities: Among other things, the FCA highlights future work in retail banking relating to fair value in SME business current accounts and consumer understanding in the credit card market.

The FCA notes its timing may change if it needs to prioritise new and emerging consumer harms for specific sectors or the industry.

Also on 30 September 2025, the FCA published a webpage providing an update on its rule review following introduction of the Consumer Duty. The FCA hosted a regulatory summit in July 2025 to discuss the proposals in its March 2025 feedback statement (FS25/2) and to help determine next steps.

The FCA has grouped the feedback it received under the following headings:

• Clarifying how the Duty applies to firms in distribution chains;
• Providing clearer guidance on the scope of rules, including the Duty;
• Ensuring the FCA co-ordinates effectively with the Financial Ombudsman Service (FOS);
• Improving consistency in rules and definitions; and
• Updating legacy disclosure rules.

The FCA has decided not to proceed with broader reviews of its product governance, client asset and training and competence sourcebooks, although it will keep this under review. It will deliver focused work this year on its systems and controls requirements relating to the management of conflicts of interests and will be taking forward reforms to the senior manager regime.

The webpage provides an overview of the complete and in-progress workstreams from FS25/2, as well as setting out the FCA’s future priorities. These relate to areas including the review of the Senior Managers and Certification Regime and modernising the consumer redress framework.

The FCA will continue to look for opportunities to streamline its requirements of firms and provide mechanisms for stakeholders to raise concerns about overly complex or overlapping requirements. It intends to run a series of sector-level roundtables during 2026 and will provide a further update on its next steps in 2026.

United Kingdom & United States: Transatlantic Task Force to align digital asset and capital markets regulation to be launched

On 22 September 2025, the UK and U.S. governments announced the creation of a Transatlantic Taskforce for the Markets of the Future, a strategic initiative aimed at deepening cooperation on capital markets and digital asset regulation. The agreement was reached during talks between UK Chancellor Rachel Reeves and U.S. Treasury Secretary Scott Bessent in Downing Street, coinciding with President Donald Trump’s state visit.

The task force will be jointly chaired by officials from HM Treasury and the U.S. Treasury, with participation from key regulators including the FCA and the SEC. It will report back within 180 days via the UK-U.S. Financial Regulatory Working Group, and will focus on:

• Short and medium-term collaboration on digital assets while legislation and regulatory regimes continue to evolve;
• Reducing cross-border capital-raising burdens for UK and U.S. firms; and
• Exploring long-term opportunities for innovation in wholesale digital markets.

The initiative forms part of a broader strategy to reinvigorate the UK’s financial services sector. HM Treasury has described the task force as a vehicle to “drive innovation and growth in global markets,” with a particular focus on shaping future regulatory frameworks for digital assets. At the same time, the move reflects the U.S.’s increasingly crypto-friendly posture under the Trump administration, which has introduced landmark stablecoin legislation and rolled back enforcement actions against major crypto firms.

United Kingdom: FCA consults on progressing fund tokenisation

On 14 October 2025, the FCA published a consultation paper setting out its plans to progress the tokenisation of funds – that is, the digital representation of interests in investment funds, using distributed ledger technology (DLT).

In outline, the main proposals in the consultation are:

• Guidance for operating a tokenised fund under the Blueprint model: The industry-led Technology Working Group (TWG) published a report in November 2023 setting out how firms can operate a tokenised unitholder register within existing legal and regulatory frameworks – known as the Blueprint model. The consultation contains additional guidance from the FCA to assist firms who wish to use the Blueprint model or more advanced models that are set out in the consultation.
• Rules and guidance for a “direct to fund” (D2F) model: The consultation sets out proposals for an alternative, streamlined dealing model for conventional and tokenised authorised funds, referred to as “direct to fund” (D2F).
• Roadmap for fund tokenisation and tokenised money market funds (TMMFs): The consultation includes details of how the FCA intends to support two use-cases that the TWG had previously identified as priority matters: (i) fully on-chain investment markets, with tokenised funds investing in tokenised securities such as fixed-income or other asset classes; and (ii) the use of TMMF units as eligible collateral in accordance with the rules for non-centrally cleared derivative contracts.
• Future tokenisation models: The consultation includes a discussion on future tokenisation models that use DLT to provide tokenised portfolio management for retail investing at scale and how regulation may need to change to be fit for the future.

The consultation closes on 21 November 2025 in respect of most of the proposals and on 12 December 2025 in respect of the future tokenisation models.

The FCA expects to publish a policy statement, which will contain final rules, in the first half of 2026.

For more on this development, take a look at this Our Thinking article.

United Kingdom: Bank of England governor publishes FT article on stablecoins

On 1 October 2025, Bank of England Governor Andrew Bailey published an article in the Financial Times signalling a notable softening in the central bank’s stance on stablecoins. Bailey wrote that it would be “wrong to be against stablecoins as a matter of principle,” acknowledging their potential to drive innovation in domestic and cross-border payment systems.

This marks a departure from Bailey’s earlier position, including his July 2025 Mansion House speech, where he stated that stablecoins were not a substitute for commercial bank money. The Bank of England has faced criticism for its earlier proposal to cap stablecoin holdings at £10,000–£20,000 for individuals and £10 million for businesses, a move industry groups have called “unworkable” and damaging to UK competitiveness.

In his latest remarks, Bailey suggested that the financial system “does not have to be organised” around the current reliance on bank lending, and that stablecoins could coexist with banks, with non-bank entities playing a larger role in credit provision.

The article also addressed operational risks, including the need for insurance schemes and resolution frameworks to protect holders in the event of insolvency. Bailey emphasised that stablecoins must be backed by risk-free assets, and must be directly exchangeable into fiat currency.

Looking ahead, Bailey confirmed that the Bank will publish a consultation paper later this year outlining a regulatory regime for UK-issued stablecoins.

Thailand: SEC to broaden scope of crypto ETFs beyond Bitcoin

On 2 October 2025, it was reported that Thailand’s Securities and Exchange Commission (SEC) has confirmed plans to expand the scope of domestic cryptocurrency exchange-traded funds (ETFs) beyond Bitcoin. The move reflects rising demand for more diverse investment opportunities in the country’s fast-growing crypto market.

Under the new framework, local mutual funds and institutional investors will be permitted to offer ETFs that include a wider range of cryptocurrencies – such as Ethereum and Solana – rather than being restricted to single-asset products. This marks a strategic move aimed at attracting institutional investors and provide more options for Thai investors who wish to diversify their portfolios with digital assets. Thailand’s first Bitcoin ETF was approved earlier in 2024, but this new initiative will open the door to a broader selection of cryptocurrencies.

Currently, Thai investors can only access crypto ETFs via licensed asset managers investing in overseas products. The new initiative would enable domestic offerings, improving accessibility and market depth. It also comes amid a 7.6% decline in the Stock Exchange of Thailand this year, prompting regulators to modernise investment options.

Australia: Government opens consultation on draft legislation to regulate digital asset platforms

On 24 September 2025, the Australian Government published the Treasury Laws Amendment (Regulating Digital Asset, and Tokenised Custody, Platforms) Bill 2025 for public consultation. The draft legislation proposes to bring digital asset platforms and tokenised custody platforms within the scope of the Corporations Act 2001, formally recognising them as financial products. The move delivers on a commitment made in the 2024–2025 Budget to modernise Australia’s digital asset regulatory framework.

The proposed regime aims to close existing regulatory gaps and provide legal clarity around digital assets and the infrastructure supporting them. It adopts a “same risk, same regulation” approach, aligning with international peers such as the EU and UK, while using Australia’s domestic concepts of “financial product” and “financial service.” Notably, the draft legislation avoids defining “digital assets” directly. Instead, it introduces references to “digital tokens” to ensure the law remains technology-neutral. Rights associated with digital tokens may be treated as financial products depending on the legal recognition of the holder’s position.

The legislation also introduces two new financial products – digital asset platforms and tokenised custody platforms – subject to existing licensing and consumer protection rules. Providers will be required to hold an Australian Financial Services Licence and comply with targeted obligations. Platforms handling less than A$5,000 per customer and processing under A$10 million annually will be exempt.

The consultation closed on 24 October 2025.

Kazakhstan: National Bank affirms CBDC and stablecoin can coexist under dual-track mode

On 3 October 2025, it was reported that the National Bank of Kazakhstan had confirmed that its central bank digital currency (CBDC), the digital tenge, and the newly launched Evo stablecoin are not in competition but are designed to serve complementary roles within the country’s digital asset ecosystem.

The Evo stablecoin, developed in partnership with Solana and Mastercard, is part of Kazakhstan’s broader strategy to become a regional crypto hub. It is issued by Intebix exchange and Eurasian Bank under the central bank’s regulatory sandbox. Meanwhile, the digital tenge, launched in 2023, is being piloted as legal tender and is expected to play a key role in interbank settlements.

According to the press report, the National Bank’s Deputy Governor stated that stablecoins like Evo are intended for specific ecosystems and private-sector use cases, while the digital tenge will serve as a sovereign payment instrument and foundation for fintech innovation. The government is working to establish the digital tenge as legal tender, with plans for broader circulation once the regulatory framework is finalised.

Poland: Parliament passes legislation introducing licensing regime for crypto-asset service providers

On 27 September 2025, Poland’s lower house of parliament (the Sejm) passed the Crypto-Asset Market Act (Bill 1424), introducing a licensing regime for crypto-asset service providers (CASPs) and aligning national regulations with the EU’s Markets in Crypto-Assets (MiCA) framework.

The bill designates the Polish Financial Supervision Authority (KNF) as the primary regulator and requires all CASPs – including exchanges, issuers, and custodians, both domestic and foreign – to obtain a KNF licence. Applicants must submit detailed documentation covering corporate structure, capital adequacy, compliance systems, risk management, and AML procedures.

Violations of the new regime could result in fines of up to 10 million Polish zlotys (approx. $2.8 million) and prison terms of up to two years. If enacted, CASPs will have a six-month transitional period to comply.

The bill now moves to the Senate for further consideration.

Scotland: The Digital Assets (Scotland) Bill introduced in Scottish Parliament

The Digital Assets (Scotland) Bill was introduced in the Scottish Parliament on 30 September 2025 as a result of the Scottish Government's Programme for Government's commitment to ‘clarify the status of digital assets as property in Scots private law, to provide greater legal certainty for individuals and for businesses including those investing in digital assets, for technology and financial start-ups, as well as for the legal sector'.

The Bill confirms that certain kinds of digital asset (like cryptocurrency) can be objects of property in Scots private law, confirms how to acquire and own these digital assets, and ensures the general principles of Scots private law apply to these digital assets. 

China: Shanghai opens digital yuan operations centre to boost cross-border payments

On 25 September 2025, it was reported that the People’s Bank of China (PBOC) has officially launched a digital yuan operations centre in Shanghai, marking a strategic milestone in the country’s central bank digital currency (CBDC) rollout. The centre will oversee cross-border payment networks, blockchain services, and digital asset platforms, reinforcing the digital yuan’s role in international finance.

The initiative reflects Beijing’s broader ambition to internationalise the yuan and reduce reliance on the U.S. dollar in global trade. Three core platforms were unveiled at the launch:

• A cross-border payments system to facilitate faster, cheaper international transactions;
• A blockchain services platform, powered by the domestic Chang’an Chain, aimed at secure and scalable financial applications; and
• A digital asset platform integrated with the Shanghai Clearing House, enabling real-time settlement of tokenised assets.

United States: NYDFS issues updated guidance on virtual currency custodians

On 30 September 2025, the New York State Department of Financial Services (NYDFS) issued guidance to update and replace the previous 23 January 2023 Guidance on Custodial Structures for Customer Protection in the Event of Insolvency. The updated guidance provides additional direction for virtual currency entities that act as custodians (VCE Custodians), particularly with regard to sub-custodians, while continuing to emphasize sound custody and disclosure practices to protect customers in the event of an insolvency or similar proceeding.

United States: U.S. Treasury seeks public comment on implementation of GENIUS Act

The U.S. Department of the Treasury issued an Advance Notice of Proposed Rulemaking on 18 September 2025 seeking public comment related to the Treasury's implementation of the GENIUS Act, since the statute tasks Treasury with issuing regulations that encourage innovation in payment stablecoins while also providing an appropriately tailored regime to protect consumers, mitigate potential illicit finance risks, and address financial stability risks. The Treasury invited the public to offer comments, including providing data and other information, that may be useful for Treasury to consider. Comments had to be received before 20 October 2025.

India: Government backs RBI digital currency initiative to modernise financial ecosystem

On 8 October 2025, it was reported that India’s Union Minister of Commerce and Industry had announced plans to introduce a digital currency backed by the Reserve Bank of India (RBI), as part of a broader effort to integrate blockchain technology into the country’s financial infrastructure.

The RBI-backed digital currency, designed to function similarly to traditional fiat, will be fully government-backed and aims to enhance transaction efficiency, security, and transparency. Each transaction will be verifiable, helping to curb illegal or untraceable transfers. The initiative draws parallels with regulated stablecoins in the U.S. under the GENIUS Act but remains sovereign in nature.

This move aligns with the RBI’s ongoing efforts to develop its central bank digital currency (CBDC), the Digital Rupee, which recently entered a retail sandbox phase. The sandbox is testing the currency’s performance in real-world retail scenarios, including merchant payments, wallet interoperability, and offline transactions. Select banks, fintechs, and merchants are participating in controlled environments across major cities.

United Kingdom: Bank of England publishes approach to innovation in AI, DLT and quantum computing

On 15 October 2025, the Bank of England (BoE) published a document that sets out its approach to innovation in AI, distributed ledger technology (DLT) and quantum computing. It has focused on these three technologies as it has identified them as being those that currently have the greatest potential to shape the UK economy and financial services.

The document covers work that the BoE has done and planned future work. For example, the BoE refers to its recently launched DLT Innovation Challenge, which engages with the private sector to better understand the implications of incorporating DLT into wholesale central bank settlement. Through this initiative, the BoE will look to determine if wholesale central bank money can be securely transacted and settled on external, programmable ledgers not controlled by the central bank.

There is also reference to the BoE’s approach to innovation in money and payments, along with the National Payments Vision and the development of a new model to deliver the next generation of UK retail payments infrastructure.

Global: FSB and IOSCO progress reports on implementation of cryptoasset regulatory framework

On 16 October 2025, the Financial Stability Board (FSB) and the International Organization of Securities Commissions (IOSCO) published complementary reports setting out high-level recommendations for the regulation and oversight of cryptoassets and global stablecoins (GSCs). An overview of the scope and findings of their reports was also published in a joint information note.

The reports are based on thematic implementation reviews carried out by the FSB and IOSCO in 2025 in over 40 jurisdictions.

The FSB's peer review focuses on financial stability and assesses the implementation progress by FSB jurisdictions and some volunteering non-FSB jurisdictions in implementing its July 2023 global regulatory framework for cryptoasset activities. The FSB has also published an interactive map showing the implementation status of each participating jurisdiction for both cryptoassets and GSCs.

The review highlights the notable progress of jurisdictions in regulating cryptoasset activities but notes slower progress to develop GSC arrangements. Overall, significant gaps and inconsistencies remain. Eight recommendations are made to assist jurisdictions as they further develop their regulatory regimes.

IOSCO's thematic review report, conducted jointly by its Fintech Task Force and its Assessment Committee, assesses the implementation of a subset of ten recommendations from IOSCO's 18 policy recommendations for crypto and digital asset (CDA) markets (November 2023). The CDA recommendations assessed were those most directly relevant to IOSCO's market integrity and investor protection objectives. Among other things, the review found that jurisdictions had made progress in implementing the key elements of the assessed recommendations and in regulating cryptoasset markets. However, risks remain within the fast-evolving cryptoasset ecosystem.

The key areas identified for continued progress include promoting greater consistency in implementation, reducing risks of regulatory arbitrage and strengthening enforcement practices. Appendix 1 to the report contains a full list of the policy recommendations.

The report is an initial assessment conducted under IOSCO's cryptoasset implementation roadmap, and its findings will inform the development of an assessment methodology for future assessments.

United Kingdom: Bank of England speech on how innovation is shaping the financial system

On 8 October 2025, the Bank of England (BoE) published a speech by Sasha Mills, Executive Director, Financial Market Infrastructure (FMI), on how innovation is shaping the UK financial system and how the BoE's approach to regulation supports responsible innovation. Key points from the speech include:

• Stablecoins could change market structures by weakening the link between money and the creation of credit (the traditional stronghold of banks), with the introduction of more market-based finance. By imposing holding limits to stablecoins, the BoE will be able to learn more about the impact on the cost and availability of credit and to reduce the risk of a disorderly transition. A consultation on regulating systemic stablecoins is due to be published by the BoE later in 2025.
• New technologies are changing the way transactions are executed and how systems interact, introducing some challenges e.g. when applying decentralised, DLT-based transaction models. Market fragmentation is also a possibility with the introduction of new platforms and protocols. To avoid resultant inefficiencies, siloed liquidity and restricted interoperability, standards will need to be established.
• The BoE addresses emerging risks by concentrating on the activities themselves, rather than solely on who performs them. This may result in regulating less in aggregate, e.g. the BoE may do less in the early stages of novel businesses, but put greater emphasis on areas that matter most.
• The Payments Vision Delivery Committee (PVDC), of which the BoE is a member, will publish its strategy for retail payments later in 2025.

European Union: Latest publications relating to MiCA

Latest publications relating to the Regulation on markets in cryptoassets ((EU) 2023/1114) (MiCA) include the following:

• On 3 October 2025, Commission Delegated Regulation (EU) 2025/1264, which supplements MiCA with regard to regulatory technical standards (RTS) on the minimum contents of the liquidity management policy and procedures for certain issuers of asset-referenced tokens (ARTs) and e-money tokens (EMTs), was published in the Official Journal of the European Union. It entered into force on 23 October 2025.
• On 10 October 2024, the European Banking Authority (EBA) published the following two opinions responding to the amendments proposed by the European Commission to its draft RTS on specifying the highly liquid financial instruments (HLFI) with minimal market, credit and concentration risk, and on the liquidity requirements of the reserve of assets under MiCA:
  • Opinion on the Commission's amendments relating to the final draft RTS to further specify the liquidity requirements of the reserve of assets under Article 36(4) of MiCA (dated 9 October 2025); and
  • Opinion on the Commission's amendments relating to the final draft RTS to specify the HLFI with minimal market risk, credit risk and concentration risk under Article 38(5) of MiCA (dated 9 October 2025).

The EBA sets out amended draft RTS in an Annex to each of the opinions and has submitted these to the Commission for endorsement, after which the final draft RTS will be subject to scrutiny by the European Parliament and the Council of the EU before being published in the Official Journal of the European Union.

European Union: European Commission drawing up plans to move supervision of crypto to ESMA

In a recent interview with the FT, Verena Ross, chair of the European Securities and Markets Authority (ESMA), confirmed that the European Commission is drawing up plans to transfer the regulation of several areas of EU financial markets, including crypto, from national authorities to ESMA.

European Union: EBA publishes report on tackling money laundering and terrorist financing risks in cryptoasset services

On 9 October 2025, the European Banking Authority (EBA) published a report on tackling money laundering (ML) and terrorist financing (TF) risks in cryptoasset services through supervision.

The report summarises lessons learned from actions taken by the EBA and by competent authorities responsible for anti-money laundering (AML) and counter-terrorist financing (CTF) relating to the identification and management of ML and TF risks associated with cryptoasset businesses. It considers the period before and immediately after the implementation of the regulatory framework introduced in December 2024 by the Regulation on markets in cryptoassets ((EU) 2023/1114) (MiCA) and the extension of the AML framework to cover custodian wallet providers and providers engaged in exchange services between virtual and fiat currencies made by the Fifth Money Laundering Directive ((EU) 2018/843) (MLD5).

The EBA calls on competent authorities to draw on the lessons learned from the report to manage the challenges and ML-TF risks associated with cryptoasset service provision. It considers that the new authorisation process should act as an effective "gatekeeper", as it enables competent authorities to verify compliance with regulatory requirements and ensure that key risks inherent in firms' business models are managed before granting authorisation.

The EBA will transfer its standalone AML and CTF powers and mandates to the Authority for Anti-Money Laundering and Countering the Financing of Terrorism (AMLA) on 31 December 2025. Following this, it intends to continue to play a key role in the crypto sector in relation to financial crime and supervisory convergence through its mandate under MiCA.

Malaysia: Fasset secures banking licence to launch Shariah-compliant digital bank

On 10 October 2025, it was announced that financial superapp Fasset received provisional approval from Malaysia’s Labuan Financial Services Authority to offer banking services in the country. The approval enables Fasset to expand from digital asset investing into full-service banking, offering deposit-taking services and zero-interest banking products via its secure, on-chain platform. Users can also invest in U.S. stocks, gold, and crypto through the app.

The licence marks a significant step in Fasset’s ambition to become one of the first stablecoin-backed Islamic digital banks, operating within a regulated framework for Shariah-compliant financial services.

India: PhonePe receives final RBI authorisation to operate as online payment aggregator

On 19 September 2025, PhonePe announced that it has received final authorisation from the Reserve Bank of India to operate as an online payment aggregator. The approval enables PhonePe to expand its merchant services, with a particular focus on small and medium enterprises across India.

The authorisation allows PhonePe to offer businesses secure, developer-friendly payment solutions, including instant onboarding and seamless checkout experiences. The company aims to accelerate financial inclusion by supporting underserved businesses with reliable digital infrastructure.

United Kingdom: IG Group secures FCA crypto licence, expanding retail offering

On 30 September 2025, IG Group announced that it had received a cryptoasset licence from the FCA, becoming the first London-listed broker to join the FCA’s crypto register. The approval marks a significant milestone in the UK’s regulated crypto sector and enables IG to expand its digital asset services.

The licence allows IG to offer direct crypto transfers in and out of its platform, introduce new trading features, and broaden its token offering with improved pricing.

United Arab Emirates: Wise secures dual payment licences to expand cross-border services

On 14 October 2025, it was reported that Wise has received regulatory approval from the Central Bank of the United Arab Emirates (UAE) to operate under two key categories: Stored Value Facilities and Retail Payment Services – Category 2. The licences mark a significant milestone in Wise’s expansion strategy, enabling it to offer its full suite of international money movement and management tools to personal and business customers in the UAE.

The approvals pave the way for the launch of Wise Account and Wise Business in the region, allowing users to send, spend, and receive money across borders with greater speed, transparency, and lower costs. Wise’s entry is expected to benefit the UAE’s diverse population by providing access to secure and efficient global financial services.

Global: Google and PayPal announce multi-year commerce collaboration

On 17 September 2025, Google and PayPal announced a multi-year strategic partnership aimed at advancing agentic shopping and frictionless commerce payments. The collaboration will combine PayPal’s payments infrastructure with Google’s Agent Payments Protocol, which uses cryptographically signed digital mandates to securely authorise both real-time and delegated purchases made by AI agents.

As part of the agreement, PayPal’s branded checkout, Hyperwallet, and Payouts solutions will be integrated across Google’s shopping and payment platforms. Additionally, PayPal’s enterprise payments division will become a key processor for card payments across major Google services, including Google Cloud, Google Ads, and Google Play.

Europe: vobapay partners with Mastercard to enable Open Banking payments

On 7 October 2025, Mastercard announced a strategic partnership with vobapay to integrate its Open Banking technology into vobapay’s platform, enabling account-to-account payments directly at checkout.

The collaboration aims to deliver a secure, real-time, and card-free digital payment experience for both consumers and businesses. By leveraging PSD2-compliant Open Banking capabilities, users can pay via bank login with strong customer authentication, reducing purchase abandonment and enabling instant payment confirmation.

For merchants, the integration offers benefits such as faster cash flow, lower transaction costs, reduced fraud risk, and higher conversion rates. The solution also supports B2B use cases, particularly for large transactions and recurring invoices, by offering improved liquidity, transparency, and security without card limits.

Europe: MoneyGram and Plaid expand Open Banking partnership

On 2 October 2025, it was reported that MoneyGram and Plaid had announced the expansion of their Open Banking partnership to Europe, building on their earlier collaboration in the United States. The move enables MoneyGram users in Europe to link and verify their bank accounts via Plaid’s Open Banking infrastructure to fund cross-border transactions directly.

The integration introduces a new digital payment option within MoneyGram’s platform, aimed at simplifying international transactions and enhancing digital access. Plaid’s technology allows users to authenticate bank details without manual input.

According to both companies, the partnership reflects a shared commitment to data protection, regulatory compliance, and financial inclusion. Plaid’s security framework is embedded within MoneyGram’s systems to safeguard user data across all transactions.

United States: FPC and X9 partner to advance faster payments standards

On 6 October 2025, the U.S. Faster Payments Council (FPC) and the Accredited Standards Committee X9 Inc (X9) announced a strategic alliance to accelerate the development and adoption of faster payments standards in the United States.

FPC, an industry-led membership organization, and X9, an ANSI-accredited standards body, aim to create secure, interoperable, and widely adopted standards that support efficient payment experiences for all stakeholders, especially business end-users. Their collaboration will address key challenges such as fraud mitigation, cross-border payments, and operational considerations.

As part of the initiative, the organisations will establish a Joint Standards Steering Committee in early 2026 to oversee collaborative standards efforts. The alliance will also leverage insights from FPC’s Work Groups on topics such as fraud mitigation, cross-border payments, and operational considerations, ensuring that new standards reflect real-world needs.

Germany: Savings banks partner with BNY Mellon for international money transfers

On 13 October 2025, it was reported that German savings banks have partnered with BNY Mellon to pilot a new solution for low-cost international money transfers outside the EU. The initiative, currently in testing at two local savings banks, enables customers to send cross-border payments of up to EUR 3,000 via the Sparkasse platform, with fees reduced from EUR 22 to EUR 5.50.

The project, reportedly named Crossmo, aims to help the banks win back market share from fintech competitors like Revolut and Wise by offering a more affordable and accessible remittance option, particularly for migrant communities sending funds to family abroad.

The collaboration leverages BNY Mellon’s global payments infrastructure, which supports transactions in over 120 currencies and offers compliant clearing through networks such as Fedwire, CHIPS, TARGET2, and CHAPS. The savings banks’ national association, DSGV, acknowledged concerns around European financial sovereignty but emphasised the need for global partners with secure and scalable capabilities.

A broader rollout of the service is expected in the coming months.

India: Revolut to launch payments platform integrated with UPI and Visa

On 8 October 2025, it was reported that UK-based fintech Revolut had announced plans to launch a payments platform in India later this year, marking its official entry into one of the world’s largest digital payments markets. The rollout will begin with 350,000 users already on a waiting list, with broader public access to follow.

The platform will support both domestic and cross-border payments, integrating with India’s Unified Payments Interface (UPI) and Visa’s network. Revolut has invested over £40 million to localise its technology and ensure compliance with India’s data sovereignty regulations, making it the only market where the company has fully localised its systems.

According to the press report, Revolut aims to reach 20 million users in India by 2030, citing the country’s digitally connected population and robust real-time payments infrastructure as key drivers. The India launch is part of Revolut’s broader international expansion strategy, which includes plans for new markets across Latin America, APAC, Africa, and the Middle East.

Middle East: Airwallex accelerates regional expansion with regulatory and partnership milestones

On 25 September 2025, global financial platform Airwallex announced a series of developments to fast-track its entry into the Middle East, including regulatory approvals, infrastructure investments, and strategic partnerships.

In the United Arab Emirates (UAE), Airwallex secured In-Principle Approval from the Central Bank of the UAE for Stored Value Facilities and Retail Payment Services (Category II) licences. This enables the company to offer multi-currency accounts, global transfers, payment acceptance, and corporate cards, with a focus on supporting SMEs. The company is preparing for a full launch with expanded local operations.

In Saudi Arabia, Airwallex received incorporation approval from the Ministry of Investment, allowing it to establish a local entity and support the Kingdom’s Vision 2030 digital economy goals.

To enhance its offering for regional merchants, Airwallex partnered with Tabby, a leading BNPL provider, to offer instalment payment options at checkout in both the UAE and Saudi Arabia. The collaboration aims to help global merchants increase conversion rates, basket sizes, and customer engagement in the region.

Latin America: Solidgate partners with EBANX to expand local payments access

On 26 September 2025, global payment orchestration platform Solidgate announced a strategic partnership with EBANX to accelerate its expansion across Latin America and other emerging markets. The collaboration enables Solidgate merchants to access local payment rails in over 13 countries, including Brazil, Mexico, Colombia, Argentina, and Peru, as well as select markets like India.

Through a single API integration, merchants can now offer popular local payment methods such as Pix, e-wallets, cash vouchers, instalments, and local and international cards. The partnership allows Solidgate clients to enter new markets more quickly, improve conversion rates, and offer payment experiences tailored to local consumer preferences.

Merchants will also benefit from domestic acquiring, higher approval rates, faster settlements, and enhanced compliance with local regulations.

Japan: Stripe partners with Mercari to expand Japan’s creative industries

On 3 October 2025, it was reported that Stripe, a global financial technology company known for its payment infrastructure, had announced its partnership with Mercari, Japan’s largest consumer-to-consumer marketplace app, to power the global expansion of Japan’s creative industries.

Following this announcement, Mercari has the possibility to offer users around the world a secure and efficient shopping experience with multiple currencies. In addition, Stripe will power Mercari’s new “Mercardi Global App”.

Tanzania: I&M Bank launches Mastercard cards on Way4 to accelerate digital payments

On 2 October 2025, it was reported that I&M Bank Tanzania, in partnership with Mastercard and OpenWay, had announced the rollout of Mastercard World Elite debit and multi-currency prepaid cards, powered by the Way4 digital payments platform. The launch aims to meet the evolving needs of Tanzania’s affluent and middle-market customers by offering enhanced payment security, lifestyle benefits, and simplified international transactions.

The Mastercard multi-currency prepaid card – among the first of its kind in Tanzania – supports ten currencies, enabling seamless global spending. Meanwhile, the World Elite debit card provides access to premium benefits such as concierge services, airport lounge access, travel insurance, and hotel privileges.

The initiative is part of I&M Bank’s broader strategy to accelerate the shift from cash to digital payments in Tanzania, where card adoption is rising in urban centres like Dar es Salaam and Arusha. By offering incentives such as travel perks and multi-currency convenience, the bank aims to encourage broader use of digital payment tools.