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The Payments Newsletter including Digital Assets & Blockchain, September 2025

23 September 2025
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The Payments Newsletter including Digital Assets & Blockchain, September 2025
Chapter
  • Chapter

  • Chapter 1

    Updated Hogan Lovells PSD3 Impacts Report
  • Chapter 2

    Regulatory Developments: Payments
  • Chapter 3

    Digital Assets Regulatory Developments
  • Chapter 4

    Market Developments
  • Chapter 5

    Surveys and Reports

Key developments of interest over the last month include: the UK government’s consultation on consolidating the Payment Systems Regulator into the FCA to streamline oversight of payment systems; the South African Reserve Bank’s proposal to allow non-bank entities direct access to the National Payment System; the UK FCA publishing a consultation on the application of its Handbook for cryptoasset activities; and the U.S. SEC and CFTC issuing joint guidance permitting spot crypto trading.

In this Newsletter:

  • Updated Hogan Lovells PSD3 Impacts Report
  • Regulatory Developments: Payments
  • Regulatory Developments: Digital Assets
  • Market Developments
  • Surveys and Reports

For previous editions of the Payments Newsletters, please visit our Financial Services practice page.

Chapter 1

Updated Hogan Lovells PSD3 Impacts Report

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With the June 2025 publication of the Council of the EU’s amended PSD3 and PSR texts, the legislative process is heading towards its final stages as inter-institutional negotiations begin. We have taken this opportunity to update our PSD3 Impacts Report to include the Council’s key proposals as we await the finalised legislation and implementation timelines. Take a look at this Our Thinking article for an overview of and link to the Report.

Chapter 2

Regulatory Developments: Payments

expanded collapse

United Kingdom: FCA consults on new risk-based exemption from SCA for contactless payments

Following a March 2025 engagement paper, on 10 September 2025 the FCA published its quarterly consultation paper no.49 (CP25/24) containing proposals relating to the introduction of a new exemption from strong customer authentication (SCA) requirements for low-risk contactless payments (see Chapter 9 and Appendices 7 and 8).

The FCA proposes to amend the existing exemption in Article 11 of the SCA Regulatory Technical Standards (RTS) by replacing the current regulatory approach of requiring payment service providers (PSPs) to implement payment limits (including single, cumulative and consecutive payment limits) with a new risk-based exemption for contactless payments.

The new exemption would be subject to a requirement for firms to have transaction monitoring mechanisms in place, in compliance with Article 2 of the SCA-RTS. As well as the risk-based factors outlined under Article 2, firms may consider additional factors which may help them identify whether a transaction poses a low risk, e.g. the payer’s normal spending or behavioural pattern, or the payer’s location.

PSPs will still be able to set their own contactless limits, including maintaining the current levels, and in its proposed amended Approach Document guidance the FCA acknowledges that it considers this can ‘provide a clear and effective way of identifying transactions that may fall within the exemption.’

The existing Article 12 exemption, enabling contactless payments at ticket gates and unattended parking terminals, will be retained because it is a 'well-understood and used exemption'.

The consultation closes on 15 October 2025. Once finalised, any changes would come into force with immediate effect. However, the FCA wants to hear from PSPs if they believe they would face any issues with this approach.

The FCA will consider any wider changes to the SCA-RTS in due course.

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

United Kingdom: FCA publishes statement on regulatory framework for workplace savings schemes

On 27 August 2025, the FCA published a statement clarifying the regulatory framework for workplace savings schemes.

The statement has been prompted by the limited take-up of workplace savings. According to the Department for Work and Pensions, only 7% of UK employers offer them - often due to concerns with perceived regulatory barriers. The statement aims to give employers, employee benefit platforms, payroll providers and savings providers clarity and reassurance that workplace savings schemes can be successfully set up and implemented to comply with current rules and legislation.

In the statement, the FCA provides information relating to matters including:

  • important factors for a savings provider to consider when complying with the Banking: Conduct of Business sourcebook (BCOBS);
  • what a savings provider or employer/payroll provider/employee benefits company should consider when carrying out Customer Due Diligence (CDD);
  • what a saving provider or employer/payroll provider/employee benefits company should consider when sharing employees' personal information; and
  • what savings providers need to consider about the Financial Services Compensation Scheme (FSCS).

There is also a reminder that savings providers must comply with the Consumer Duty when offering workplace saving products.

United Kingdom: Bank of England speech – ‘Building trust and supporting innovation in the multi-money verse’

On 3 September 2025, the Bank of England (BoE) published a speech by Sarah Breeden, BoE Deputy Governor, Financial Stability, on innovation in money and payments.

The speech sets out Ms Breeden’s vision for a “multi-money” system where different forms of money including traditional and tokenised commercial bank deposits, stablecoins and central bank money are freely exchangeable. She emphasises that in order to maximise benefits (eg by allowing innovation to thrive in a competitive environment) as well as safeguard financial stability and trust in all forms of money, this system must be underpinned by interoperability. This means that both the hard, technical infrastructure and the ‘soft’ infrastructure such as regulatory standards will need to be harmonised – or at least compatible – across different forms of money, ‘allowing them to be freely and frictionlessly exchanged at par’. As discussed in another speech earlier this year, Ms Breeden also makes the point that ‘interoperability and harmonisation could lay the necessary groundwork for much needed improvements in cross-border payments’.

Some other key points from the speech include:

  • The BoE will consult later in 2025 on some revisions to its November 2023 proposals on a regulatory regime for systemic stablecoins. This will include allowing systemic stablecoins to hold a portion of their backing assets in a subset of high-quality liquid assets (HQLA) (for example, short-dated government securities). The proposed change is designed to address concern that the BoE's previous approach would harm a common business model of stablecoin issuers that relies on income from backing assets.
  • The BoE plans to further explore wholesale financial market use cases for stablecoins in its Digital Securities Sandbox (DSS) by considering how stablecoins could be used as the "cash leg" for settling securities issued in the DSS.
  • There is reference to the launch in April this year of the BoE's new real-time gross settlement (RTGS) service, referred to as RT2. RT2 enables settlement in central bank money for assets traded and settled in other systems (including those traded "on-chain" in programmable and distributed ledgers (DLT)). In 2026, the BoE will launch its synchronisation lab, which will allow the full integration of central bank settlement with transactions recorded on other ledgers (including both programmable and distributed ledgers).
  • The design phase of the BoE’s Digital Pound project has allowed it to explore the potential for central bank provision of retail infrastructure, by developing a blueprint for how a digital pound could work. This blueprint is due to be published in 2026 and will set out the key design elements necessary to support the BoE and HM Treasury in assessing the policy case for a digital pound. There is also a mention of the Digital Pound Lab, launched in August 2025, which allows the BoE to explore the role of central bank provided infrastructure in supporting private sector innovation and gives the private sector a place to innovate and experiment.

For more on the BoE’s speech, take a look at this Our Thinking article.

United Kingdom: HM Treasury consults on a new consolidated regulatory framework for payment systems

In line with the UK government’s growth and competitiveness agenda and wider related work to create a more agile regulatory environment, enhance the retail payments ecosystem and support the digitalisation of wholesale financial markets, on 8 September 2025 HM Treasury (HMT) published a consultation setting out the proposed policy approach to consolidating the Payment Systems Regulator (PSR) within the FCA.

The government’s overarching aim is to move to a more streamlined regulatory framework for payment systems, with a reduced number of regulators in order to reduce both the regulatory burden on participants (who can find themselves regulated by more than one regulator for different purposes and activities) and overlap/duplication in the work of the regulators.

The current consultation does not cover all of the issues associated with the new consolidated regulatory framework. The focus is on the proposed approach to some core design decisions where the government believes it would be most useful to receive stakeholder feedback. Key points from the consultation proposals include the following:

  • The FCA will take on the PSR’s responsibilities as economic regulator for UK payment systems via legislation integrating the PSR’s functions within the FCA’s current Financial Services and Markets Act (FSMA) 2000 framework (or in a new part of FSMA 2000);
  • An HMT designation regime will be retained for persons currently subject to the Financial Services (Banking Reform) Act (FSBRA) 2013 regime, namely payment systems and the participants in those systems – payment system operators, infrastructure providers and payment service providers;
  • The FCA’s statutory objectives and regulatory powers in relation to payment systems would be broadly equivalent in scope and substance to those of the PSR; and
  • The government is considering simplifying the current framework for governing access to payment systems by ensuring there is a single access regime that applies in all relevant circumstances, based on the provisions currently under Part 5 of FSBRA 2013.

The consultation closes on 20 October 2025. Following consideration of stakeholder feedback, legislation will be brought forward to implement the government’s final policy when Parliamentary time allows.

For more on HMT’s consultation, take a look at this Our Thinking article.

United Kingdom: HM Treasury publishes policy note and draft SI on amendments to the Money Laundering Regulations

On 2 September 2025, HM Treasury (HMT) published a draft statutory instrument (SI) and policy note on amendments to the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (SI 2017/692) (MLRs) and opened a technical consultation. These publications follow on from its July 2025 response to its March 2024 consultation paper on improving the effectiveness of the MLRs.

HMT is seeking feedback on the practical operability, clarity and effectiveness of the draft provisions in the SI. The policy note summarises the main measures and their policy intent and groups them according to the chapter of the consultation response in which they were set out, including:

  • Enhanced due diligence on complex transactions and high-risk third countries, and due diligence in pooled client accounts and triggers for certain non-financial firms;
  • Customer onboarding in bank insolvency scenarios and information sharing between supervisors and other public bodies; and
  • Registration and change of control for cryptoasset service providers.

The consultation closes on 30 September 2025. The final SI is expected to be laid in early 2026 and come into force 21 days later. Specific provisions for cryptoasset businesses will be aligned with the commencement of the cryptoasset perimeter under the Financial Services and Markets Act 2000 (FSMA).

South Africa: South African Reserve Bank to open payments system access to non-bank entities

On 31 August 2025, it was reported that the South African Reserve Bank plans to unveil proposals that would allow non-bank entities direct access to the country’s National Payment System, which facilitates inter-institutional money transfers.

Under the current framework, non-banks must partner with commercial banks to clear and settle payments. The proposed reforms, expected in the first half of 2026, aim to end the existing monopoly held by commercial lenders and promote greater competition, efficiency, innovation, and financial inclusion within South Africa’s payments ecosystem.

This initiative aligns with global trends in real-time payments, where non-banks are increasingly entering the space traditionally dominated by financial institutions.

India: National Payments Corporation of India expands payment infrastructure to widen credit access

On 29 August 2025, it was reported that the National Payments Corporation of India (NPCI), which operates the Unified Payments Interface (UPI), has begun offering its digital payments infrastructure to banks to facilitate short-term lending to small businesses.

Currently, UPI enables instant money transfers between bank accounts and has become one of the most widely used payment systems in India, handling over 600 million transactions per day as of July 2025. It forms part of India's broader digital infrastructure strategy, known as India Stack, which supports identity verification, benefit distribution, and mobile payments for the country's 1.4 billion people. NPCI's latest initiative aims to extend UPI's functionality beyond payments to allow banks to use the platform to offer short-term loans directly to users' UPI apps.

The move is intended to promote financial inclusion and improve access to credit. Despite high levels of bank account ownership, a significant portion of accounts remain inactive. NPCI's initiative seeks to address this gap by integrating credit services into a platform already widely adopted for daily transactions.

Nigeria: Central Bank of Nigeria sets October 2025 deadline for payment messaging compliance

On 25 August 2025, the Central Bank of Nigeria issued a directive requiring all commercial banks, microfinance banks, mobile money operators, and other licensed payment service providers in Nigeria to fully migrate to the ISO 20022 standard for financial messaging by 31 October 2025.

Financial institutions must ensure complete and accurate population of mandatory data fields, including payer/payee identifiers, merchant or agent details, and relevant transaction metadata.

Additionally, geo-tagging of all payment terminals is now mandatory, supported by double-frequency GPS receivers, to ensure reliable location detection. Terminals must also be registered with a Payment Terminal Service Aggregator (PTSA), tagged with precise latitude and longitude coordinates indicating the place of business and must be certified by the National Central Switch. Terminals not routed through a PTSA will be prohibited from processing transactions.

The compliance validation exercises will commence on 20 October 2025. The move aligns Nigeria’s payment messaging infrastructure with global SWIFT standards and marks a major step in modernising Nigeria’s payments infrastructure.

Australia: Reserve Bank of Australia signals flexibility on card payment reforms

The Reserve Bank of Australia (RBA) has indicated it may adjust its proposed overhaul of card payment reforms to account for small payment providers and fintechs, following feedback that the proposed changes could hinder their ability to compete and innovate.

This followed the release of a consultation paper on 15 July 2025, in which the RBA proposed significant changes to card payment costs and surcharging rules. Among the key proposals is a potential ban on credit and debit card surcharges, which the RBA estimates could save consumers AUD 1.2 billion annually. However, the reforms have drawn criticism from industry groups, who warn that removing surcharges could lead to price increases or job losses, particularly for smaller businesses that may struggle to absorb card processing costs.

In an update following the RBA’s Payments System Board meeting on 28 August 2025, the Board acknowledged these concerns and confirmed that preliminary discussions were to be held on whether to reduce card payment regulations on small issuers and how best to support this objective.

While no final decision has been made, the Board confirmed that the issue will be considered further during the ongoing consultation process.

United States: CFPB restarts open banking overhaul

On 21 August 2025, the U.S. Consumer Financial Protection Bureau (CFPB) reportedly restarted its rulemaking process on open banking regulations, which govern how consumers share personal data between banks and third-party providers, including fintech platforms and crypto platforms (see more in our August edition). The move follows pressure from the fintech and digital currency sectors, and marks a reversal from earlier positions taken by the Trump administration, which initially sought to scrap the revised rules introduced under the Biden administration. The current administration now supports revisiting the framework in light of recent market developments.

The original rules, introduced under the Dodd-Frank Act, aimed to promote competition and reduce consumer costs by allowing consumers to switch financial providers more easily. The revised process will re-examine key issues, including:

  • Who may access consumer data on their behalf;
  • Whether banks can charge fees for data access; and
  • How to manage risks related to data breaches.

Colombia: Launch of Bre-B payment system delayed to October 2025

On 31 August 2025, it was reported that the launch of Colombia’s centralised payment platform, Bre-B, will not begin operations in September as previously scheduled. The launch has reportedly been rescheduled to 9 October 2025.

This marks the fourth delay for Bre-B, which was initially expected to launch between March and May 2025, before being pushed to July, then mid-September, and now October. The delays have been attributed to ongoing technological adjustments and the need for a carefully managed implementation process.

Bre-B is designed to modernise Colombia’s payments infrastructure by enabling 24/7 account-to-account transactions. The platform will also connect banks, digital wallets, and payment processors, integrating new solutions from entities such as Credibanco and Visionamos, the cooperative financial network. Once launched, Bre-B is expected to significantly enhance interoperability across the financial system.

Barbados: Montran selected to build Barbados’ Instant Payment System

On 5 September 2025 Montran, a global provider of financial infrastructure solutions, announced that it has been selected by the Central Bank of Barbados (CBB) to design and implement the country’s new Instant Payment System. The initiative forms part of the Barbados Payments System Modernisation Project, which is supported by the World Bank and aims to enhance financial infrastructure, speed, and inclusion across all sectors.

European Union: European Commission publishes second report on assembling payment account data under PAD

On 11 September 2025, the European Commission published its second report on assembling specific payment account related data from member states under Article 27 of the Payment Accounts Directive (2014/92/EU) (PAD). The report covers information relating to 2022 and 2023, as well as complete data for 2021 that was not available at the time of the first report.

The report notes that significant data gaps and differences in data collection methods make it difficult to draw firm conclusions on the impact of the PAD. However, the Commission’s observations include the following:

  • The main measures of the PAD relating to transparency and comparability, the switching service, and the right to a payment account with basic features are all generally in place.
  • The information and transparency requirements under the PAD are generally being complied with, suggesting an overall reduction in consumer detriment.
  • Payment account switching is being used more in some member states than others. There are also significant differences across member states in the number of switching applications that are refused.
  • The number of new account openings for payment accounts with basic features (PABFs) differs significantly across member states.

The Commission plans to follow up with member states on the report findings, including the low uptake of the switching service or high rejection rates for PABFs in some member states. It will explore whether further actions might be beneficial, including at member state level, and will also continue to work with member states to improve the quality of the data provided.

United Kingdom: FCA shares findings on authorisation and registration applications

On 11 September 2025, the FCA shared examples of good practice and areas for improvement from the applications for authorisation or registration that it has seen.

The FCA divided its findings into three main areas of focus, namely that firms are able to demonstrate in their applications that they have:

  • staff with the appropriate skills, experience and capacity to provide the relevant financial service;
  • robust policies that document their processes and procedures; and
  • financial resources that are appropriate for the nature and scale of their business.

On the basis of the volume of points for improvement in the findings, it would appear that firms’ ability to show that they have robust policies in place is a particular weak spot in applications received by the FCA to date.

The FCA points out that its findings should be read alongside the other relevant authorisation information for firms on its website.

Take a look at this Our Thinking article for more on the FCA's findings.

Chapter 3

Digital Assets Regulatory Developments

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United Kingdom: FCA publishes consultation on application of FCA Handbook for cryptoasset activities

On 17 September 2025, the FCA published a consultation paper (CP25/25) on the application of existing FCA Handbook rules to cryptoasset firms that will be regulated under the incoming regime in accordance with the draft statutory instrument published earlier this year (see our previous Our Thinking article here).

In terms of its overarching approach, the FCA intends to apply the majority of existing FCA Handbook rules and guidance to cryptoasset firms in a similar way to how those rules apply to traditional providers of investment services such as brokers, dealers and investment intermediaries.

In outline, the consultation covers:

  • Consultation proposals (Chapters 1-5 of the consultation) on the application of rules and guidance from cross-cutting FCA Handbook areas to cryptoasset firms, such as the Principles for Business (PRIN), Senior Management Arrangements, Systems and Controls (SYSC), etc. as well as non-Handbook guidance on operational resilience - the FCA is seeking feedback on the consultation proposals by 12 November 2025; and
  • Discussion elements (Chapters 6-7 of the consultation) in relation to the application of the Consumer Duty, conduct of business and product governance sourcebooks to cryptoasset firms, as well as access to the Financial Ombudsman Service - the FCA is seeking feedback on the discussion elements by 15 October 2025.

Take a look at this Our Thinking article for a breakdown of the key components of the consultation paper.

South Korea: Government to implement OECD’s Crypto-Asset Reporting Framework

On 2 September 2025, it was reported that South Korea’s Ministry of Economy and Finance is advancing plans to implement the OECD’s Crypto-Asset Reporting Framework (CARF), a global initiative aimed at curbing offshore tax evasion through automatic exchange of crypto transaction data among national tax agencies. CARF has already been adopted by 48 other jurisdictions, including the UK, Germany, and Japan.

Under the framework, Korean exchanges such as Upbit and Bithumb will be required to report foreign users’ personal and transactional data to their respective tax authorities starting in 2026. In return, overseas exchanges will share Korean users’ crypto activity with the National Tax Service (NTS). The first exchange of data is scheduled for 2027, covering transactions from 2026. The initiative will significantly expand oversight of cross-border crypto holdings.

Separately, it has been reported that on 19 August 2025 the Financial Services Commission ordered all domestic exchanges to suspend crypto lending services with immediate effect, citing investor protection and market stability concerns. The moratorium will remain in place until a comprehensive regulatory framework for digital asset lending is finalised.

Thailand: Finance Ministry to launch government bond-backed stablecoin

On 15 September 2025, it was reported that Thailand’s Finance Ministry is set to announce plans to launch a 10 billion baht stablecoin backed by government bonds. The initiative is aimed at expanding public access to investment opportunities and improving market liquidity through the tokenisation of government bonds.

The stablecoin will be issued against newly released government bonds and traded via a centralised platform designed for secondary market transactions, under the oversight of the Public Debt Management Office. The platform is intended to make bond investments, typically limited to institutional or high-net-worth investors, more accessible to retail participants.

Taiwan: Financial Supervisory Commission advances draft law on virtual asset services

On 27 August 2025, Taiwan’s Financial Supervisory Commission (FSC) was reported to have announced the advancement of a comprehensive draft law regulating virtual asset services. The legislation was submitted to the Executive Yuan, Taiwan’s cabinet, in June and is now awaiting review by the Legislative Yuan, Taiwan’s parliament.

The proposed law aims to establish a formal regulatory framework for digital asset operations, including requirements for auditing, information disclosure, and oversight. The FSC confirmed that the draft was developed in close consultation with the Central Bank and addresses key areas including digital asset auditing and information disclosure requirements.

Japan: Financial Services Agency to launch dedicated bureau for crypto and digital finance oversight

On 21 August 2025, Japan’s Financial Services Agency (FSA) is reported to have confirmed its plans to launch a new regulatory bureau focused on insurance, cryptoassets and digital finance, with operations expected to begin in 2026 (see this excerpt from the related press conference). The move is part of a broader structural reform of the FSA – its first major reorganisation since 2018 – and reflects Japan’s ambition to become Asia’s leading hub for digital finance and asset management.

Under the new framework, the bureau will assume responsibility for:

  • Supervising cryptocurrencies and digital financial products;
  • Developing tailored rules and guidelines to support innovation while ensuring investor protection; and
  • Providing consistent oversight as digital finance grows in complexity and scale.

The FSA also plans to appoint a Supervisory Planning Officer to oversee credit unions and cooperatives. This follows recent improper lending practices.

Officials emphasised that digital innovation requires a dedicated regulatory framework and robust supervision. The reform also aims to enhance regulatory transparency, market governance, and public trust in Japan’s evolving financial system.

China: Authorities explore yuan-backed stablecoins to support global currency usage

On 20 August 2025, it was reported that Chinese authorities are considering the development of yuan-backed stablecoins as part of a broader strategy to increase the global use of the Chinese currency. This marks a major reversal of China’s previous stance on digital assets, which included a ban on cryptocurrency trading and mining in 2021, and is aimed at strengthening the yuan’s role in cross-border trade and digital finance.

According to the report, sources familiar with the matter indicated that the proposed stablecoins would be backed by offshore yuan reserves and could be issued through state-linked financial institutions.

The State Council, China's cabinet, is expected to review and potentially approve a roadmap later this month. The roadmap will set targets for global yuan usage, define the responsibilities of domestic regulators and include risk prevention guidelines.

Details of the plan are expected to be disclosed in the coming weeks, with implementation responsibilities likely to be assigned to Chinese regulators, including the People's Bank of China.

Philippines: Central bank extends moratorium on new VASP licences indefinitely

On 28 August 2025, the Bangko Sentral ng Pilipinas (BSP) announced an indefinite extension of its moratorium on the issuance of new licences for Virtual Asset Service Providers (VASPs). The moratorium was originally introduced in September 2022 for a three-year period and was set to expire in 2025.

The BSP cited the need to strengthen regulatory oversight and ensure market stability amidst the heightened risks associated with digital assets as key reasons for the extension.

In its statement, the central bank emphasised: “The BSP will periodically review the moratorium on VASP licensing in line with industry developments, as it strengthens its monitoring, surveillance, and enforcement capabilities.”

United States: SEC and CFTC issue joint guidance permitting spot crypto trading

On 2 September 2025, the U.S. Securities and Exchange Commission (SEC) and the Commodity Futures Trading Commission (CFTC) released a joint statement outlining a coordinated approach to regulating spot crypto trading.

The statement clarifies the view that current law does not prohibit SEC-registered national securities exchanges or CFTC-registered exchanges from facilitating trading in spot crypto commodity products.

Other key takeaways include:

  • The SEC and CFTC are encouraging engagement from market participants and have pledged support for prompt review of proposals. The commissions announced they will quickly review exchange filings or requests to list spot crypto products and “stand ready to engage” with firms on any regulatory questions.
  • In the commissions’ view, clearing houses may partner with custodians to manage customer accounts. Both the SEC and CFTC are open to addressing regulatory questions from registered clearing agencies and derivatives clearing organisations.
  • The agencies encouraged the sharing of reference pricing venues among national securities exchanges (NSEs), designated contract markets (DCMs), and foreign boards of trade (FBOTs) to strengthen market oversight.
  • Public transaction reporting by NSEs and DCMs is seen as a positive step towards improving market transparency.
  • The agencies emphasised that the statement reflects staff views only and does not carry legal force or effect. It does not introduce any new rules or exemptions, nor does it create a legal safe harbour.

The statement builds on the President’s Working Group on Digital Asset Markets recommendations published in July this year, which directed the SEC and CFTC to provide clarity on the delineation of regulatory responsibilities and emphasised the importance of keeping blockchain innovation within the U.S. (see more in our August edition).

European Union: ESMA calls for safeguards as tokenised securities gain traction

On 2 September 2025, the European Securities and Markets Authority (ESMA) highlighted the need for robust safeguards as tokenisation continues to reshape financial markets. In a speech delivered by ESMA’s Executive Director, Natasha Cazenave, she acknowledged that while tokenisation – representing financial instruments on distributed ledgers – has the potential to transform capital markets, it must evolve within a framework that protects investors and preserves financial stability.

To address the risks of tokenisation, Cazenave pointed to the EU’s DLT Pilot Regime, which provides a legal framework for the trading and settlement of certain cryptoassets. Cazenave described the regime as offering a regulatory sandbox where market participants and supervisors could test approaches under controlled conditions. ESMA has proposed amendments to make the pilot regime permanent and more flexible, including tailoring thresholds and eligible assets to the specific risks of different business models.

European Union: Delegated and Implementing Regulations on RTS and ITS under MiCA published in OJ

On 15 September 2025, the following two Regulations supplementing the Regulation on markets in cryptoassets ((EU) 2023/1114) (MiCA) were published in the Official Journal of the European Union (OJ):

  • Commission Delegated Regulation (EU) 2025/1125 of 5 June 2025 supplementing MiCA with regard to regulatory technical standards (RTS) specifying the information in an application for authorisation to offer asset-referenced tokens (ARTs) to the public or to seek their admission to trading (developed under a mandate in Article 18(6)); and
  • Commission Implementing Regulation (EU) 2025/1126 of 5 June 2025 laying down implementing technical standards (ITS) for the application of MiCA with regard to the establishment of standard forms, templates and procedures for the information to be included in the application for authorisation to offer ARTs to the public and to seek their admission to trading (developed under a mandate in Article 18(7)).

Both Regulations will enter into force on 5 October 2025.

United States: CFTC opens pathway for Americans to trade on offshore crypto exchanges

On 28 August 2025, the Commodity Futures Trading Commission (CFTC) announced that offshore crypto exchanges may now legally serve U.S.-based clients by registering under the Foreign Board of Trade (FBOT) framework. This move is part of the CFTC’s broader “crypto sprint” initiative to modernise digital asset regulation and support the Trump administration’s digital finance agenda (see the August edition of our Newsletter).

The FBOT framework, which has existed since the 1990s, allows foreign exchanges to offer services to U.S. clients across asset classes, provided they meet certain regulatory standards.

United States: House of Representatives proposes CBDC ban as part of National Defense Authorization Bill

On 22 August 2025, it was reported that the U.S. House of Representatives had added a provision to the National Defense Authorization Act (NDAA) that would ban the Federal Reserve from issuing or developing a central bank digital currency (CBDC) for the fiscal year 2026. The NDAA is considered “must-pass” legislation as it outlines how the military will be funded, and lawmakers often use it to advance contentious measures that may not succeed independently.

The provision would prohibit the Federal Reserve from creating, testing, or implementing any digital currency or asset, and from offering financial services directly to individuals. However, it includes a carve-out for stablecoins, allowing dollar-denominated currencies that are “open, permissionless, and private.”

The move follows the House’s earlier passage of the Anti-CBDC Surveillance State Act in July, which passed narrowly and faces an uncertain future in the Senate (see further information in our August newsletter). The inclusion of the CBDC ban in the NDAA reflects broader Republican efforts to block CBDCs, aligning with a January 2025 Executive Order from President Donald Trump prohibiting their development.

Global: Wolfsberg Group guidance on providing banking services to fiat-backed stablecoin issuers

On 8 September 2025, the Wolfsberg Group published guidance setting out a framework for managing financial crime risks when providing banking services to fiat-backed stablecoin issuers.

According to the guidance, most of the same financial crime risk management principles apply in developing and monitoring a relationship with any type of bank or non-bank financial institution. However, there are also unique financial crime risks associated with the provision of banking services to fiat-backed stablecoin issuers operating in a regulated jurisdiction. These risks are explored in the guidance, which also establishes a framework intended to enable financial institutions to manage them appropriately.

Chapter 4

Market Developments

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Vietnam: Government approves first crypto sandbox trial for asset conversion

On 27 August 2025, it was announced that Vietnam’s government approved Basal Pay, Vietnam’s first crypto asset conversion platform, to operate within Da Nang’s controlled fintech sandbox.

Developed by AlphaTrue Solutions JSC, a member of the Vietnam Blockchain and Digital Asset Association, Basal Pay is designed to facilitate instant conversion between crypto assets and fiat currency, reducing transaction costs by up to 30%. It features a three-tier identification system, automatic data transmission, and five-year record retention to support regulatory oversight. The project will undergo a 36-month testing roadmap, evaluation, under the supervision of Da Nang’s Department of Science and Technology.

Basal Pay is part of Vietnam’s broader push to accelerate the implementation of Politburo Resolution No. 57/NQ-TW and National Assembly Resolution No. 222/2025/QH15, which aim to reduce legal barriers, promote innovation, and establish Da Nang and Ho Chi Minh City as international financial centres.

United Kingdom: Wise explores full banking licence to expand payments infrastructure

On 1 September 2025, it was reported that Wise is exploring the possibility of becoming a fully licensed UK bank, a potential shift from its origins as a money transfer service. While no formal application has been submitted to the Bank of England or the FCA, the company has reportedly approached senior financial services professionals about roles related to a UK banking operation.

Permission to accept deposits would enable Wise to offer bank accounts and pay interest on the deposits they take, and gain direct access to payment systems like CHAPS, reducing reliance on third-party providers and lowering operational costs.

Europe: EuroPA and EPI partner to expand cross-border payments

Following their initial partnership announcement in June 2025, mobile payment alliance EuroPA – comprising Bancomat, Bizum, MB WAY (SIBS), and Vipps MobilePay – and the European Payments Initiative (EPI) confirmed on 1 September 2025 that the exploratory phase of their collaboration is nearing successful completion.

The initiative aims to interconnect existing mobile payment solutions via a central technical hub, enabling over 120 million users to make instant, cross-border payments while continuing to use their preferred brands. The hub will support peer-to-peer and commercial transactions, leveraging European standards such as instant account-to-account payments.

A feasibility study is expected to conclude by December 2025, after which implementation will begin. The rollout will start with P2P transfers and expand to other use cases. The initiative will initially span 13 European markets, including Andorra, Belgium, Denmark, Finland, France, Germany, Italy, Luxembourg, Netherlands, Norway, Portugal, Spain, and Sweden, and supports the goal of building a sovereign, interoperable European payments ecosystem.

United States: PayQuicker launches same-day ACH for faster payouts

On 26 August 2025, PayQuicker announced that it has expanded its real-time payout capabilities by launching same-day ACH (Automated Clearing House) transfers for payees in the U.S. Same-day ACH allows payments to settle within hours instead of days, helping organisations improve efficiency and meet payees’ financial needs. The feature will be available to select users across industries such as gig economy, affiliate marketing, direct selling, and clinical trials, where fast and secure payments are key.

Global: Mastercard and Infosys partner to scale cross-border payments

On 28 August 2025, Mastercard announced that it has partnered with Infosys to expand access to Mastercard Move – its global money movement platform – via integration with Infosys Finacle. This will play a key role in creating an efficient pathway for financial institutions to access Mastercard Move’s cross-border capabilities in less time and without the intensive resourcing traditionally needed for integration projects.

The partnership helps banks deliver faster, more secure payment experiences and also supports Mastercard’s broader goal of scaling the reach of remittance services, especially in high-growth regions like Asia, which accounted for nearly half of global inflows in 2024.

South America: Rappi and AstroPay launch wallet-on-file integration

On 2 September 2025, Astropay announced it has partnered with Latin American delivery company Rappi to launch the region’s first wallet-on-file integration, now live in Argentina, Brazil, and Peru. The feature enables instant checkout using balances in USD, EUR, or local currencies, with real-time FX conversion and no card-related delays.

With this initiative, Rappi aims to reduce processing costs and increase conversion. The integration supports Latin America’s fast-growing cross-border payments market and reflects the rise of embedded payments in mobile-first economies.

Saudi Arabia: Thunes launches real-time cross-border payments

On 16 September 2025, it was reported that Thunes had announced the launch of its real-time cross-border payments solution in Saudi Arabia, enabling instant payouts directly to bank accounts and digital wallets in Saudi Riyals (SAR). This initiative is part of Thunes’ broader strategy to improve international payment accessibility and efficiency across emerging markets.

According to Thunes’ 2025 Report: Money Without Borders, 65% of expatriates consider transaction speed a key factor when choosing how to send money. By connecting directly with the Saudi banking infrastructure, Thunes aims to support the Kingdom’s shift towards digital financial services and meet growing demand for reliable cross-border payment options.

Thunes is also planning to introduce a “Me2Me” service, allowing individuals to top up accounts or wallets in their home country directly from their domestic banking apps, a feature designed to meet the needs of the 15% of expats who send money back to themselves.

Japan: GoPay now offers QRIS payments in Japan

On 16 September 2025, it was reported that GoPay had enabled QRIS payments in Japan, allowing Indonesian travellers to make purchases at Japanese merchants by scanning JPQR codes using the GoPay app. This development follows Bank Indonesia’s expansion of its cross-border QR code payment system to Japan.

GoPay, operated by GoTo Financial, already supports QRIS payments in Thailand, Malaysia, and Singapore. The move to Japan is part of broader efforts to scale QRIS cross-border payment access and simplify international transactions for Indonesian users.

It has also been reported that Bank Indonesia is also conducting a pilot to connect QRIS with China’s payment systems, with a full launch targeted by the end of 2025.

Africa: Onafriq and Visa offer Visa Pay in Africa

On 11 September 2025, Onafriq, Africa’s largest digital payments network, announced that it has partnered with Visa to launch Visa Pay, a cloud-native Payments-as-a-Service platform in the Democratic Republic of Congo (DRC). The solution enables consumers in the DRC to fund Visa Pay wallets directly from mobile money channels, offering seamless access to digital and e-commerce payments.

Powered by Onafriq’s APIs, the platform supports mobile money collections and disbursements from M-Pesa, Airtel Money, and Orange Money wallets, expanding Visa’s reach to millions of users. The initiative aims to drive financial inclusion by integrating Visa Pay with existing mobile money infrastructure and promoting interoperability.

Alongside the DRC rollout, the partnership sets the stage for Visa Pay’s expansion into other African markets, where mobile money adoption continues to grow and demand for interoperable, digital-first solutions is rising.

Mexico: OpenFX launches cross-border payment platform

On 28 August 2025, it was reported that OpenFX had announced the rollout of its cross-border payment platform in Mexico, aiming to provide domestic companies with faster, cost-effective access to global FX markets and international companies with near real-time currency conversion. While transaction fees have long been seen as the main barrier to global trade, delays are a greater obstacle, tying up working capital. By reducing this time to minutes, the platform helps Mexican businesses reinvest more in expansion.

The launch follows a USD 23 million funding round and forms part of OpenFX’s plan to expand to over 40 countries and 15 G20 currency pairs by the end of 2025.

Singapore: 2C2P secures Major Payment Institution licence

On 26 August 2025, full-suite payments platform 2C2P announced it has been granted a Major Payment Institution licence by the Monetary Authority of Singapore under the Payment Services Act 2019. The licence enables the company to offer domestic and cross-border money transfer services, as well as merchant acquisition services to businesses in Singapore.

The move supports 2C2P’s regional expansion and strengthens its role in Southeast Asia’s digital payments ecosystem, following recent partnerships in Malaysia’s travel industry.

Peru: PIX introduced to boost Brazilian tourism

On 27 August 2025, it was reported that Online IPS has launched, in partnership with INCUSE and SKÅL Cusco, Brazil’s instant payment system, PIX, to Peru’s tourism sector. The initiative aims to improve travel experiences for Brazilian tourists by offering familiar payment options, strengthen Peru’s digital payment infrastructure and foster regional collaboration in Latin America’s hospitality industry.

Canada: Walmart launches Klarna BNPL for in-store payments

On 25 August 2025, Walmart Canada announced that it has partnered with Klarna to offer Buy Now, Pay Later (BNPL) options at over 400 stores, expanding its existing online offering. Customers can now pay in-store via QR code at checkout, choosing between Pay in Full or Pay in 4 for purchases over CAD 50.

The move responds to growing demand for flexible payments in Canada, where the BNPL market is projected to reach USD 11.32 billion by 2030.

European Union: Klarna expands debit-first card across Europe

On 2 September 2025, Klarna announced the launch of its debit-first Klarna Card in ten European markets, including Austria, Belgium, Finland, France, Ireland, Italy, the Netherlands, Portugal, Spain, and Sweden. The card allows consumers to pay upfront anywhere Visa is accepted, while also offering flexible options like Pay in 3, Pay Later and longer-term financing via the Klarna app.

The launch follows a successful rollout in the U.S., where 685,000 users have signed up since July. Klarna plans further expansion across Denmark, Germany, Norway, and Poland as part of its growing card-based product portfolio.

Poland: TrueLayer now available in Poland

On 2 September 2025, TrueLayer announced it has officially launched in Poland, marking its 22nd live market and adding the Zloty as its third supported currency alongside GBP and EUR. This will allow Polish businesses to sign up for its instant payouts product, offering faster settlements, reduced costs, improved success rates, and real-time reconciliation.

The launch is part of TrueLayer’s broader European growth strategy, which recently included an expanded partnership with Stripe to support Pay by Bank in France and Germany.

Global: BNP Paribas and HSBC join privacy-focused blockchain Canton Network

On 9 September 2025, it was reported that BNP Paribas and HSBC have joined the Canton Network, a privacy-centric blockchain, widely adopted by banks and financial institutions.

Their entry follows recent additions like Goldman Sachs, Hong Kong FMI Services, and Moody’s Ratings in March. The network now reportedly hosts over USD 3.6 trillion in tokenized assets.

BNP Paribas cited the move as part of its digital transformation strategy, focusing on blockchain applications in client services, while HSBC highlighted its potential to enhance liquidity in digital asset markets and support multi-asset transactions.

Brazil: Itaú Asset Management launches dedicated crypto division

On 6 September 2025, it was reported that Itaú Asset Management, Brazil’s largest private asset manager, has launched its first dedicated cryptocurrency division, marking a significant expansion of its digital asset capabilities.

The new division will operate within Itaú’s multidesk investment structure, which oversees more than 117 billion reais (USD 21.6 billion) across 15 trading desks. It is expected to introduce a range of products, from fixed-income-style instruments to higher-risk funds tied to derivatives.

Bermuda: Haycen secures stablecoin issuance licence in Bermuda

On 22 August 2025, it was reported that Haycen, a fintech infrastructure provider, has received a stablecoin issuance licence from the Bermuda Monetary Authority (BMA). The licence allows Haycen to issue stablecoins in multiple currencies.

Chapter 5

Surveys and Reports

expanded collapse

Open banking hits record 15 million users in the UK

On 2 September 2025, Open Banking Limited (OBL) announced it has hit 15.16 million UK users now using open banking services as of July 2025 – equivalent to nearly one in three UK adults. This marks the fastest growth in adoption to date, with user numbers growing by 34% in the last year and over 2.04 billion service interactions recorded in July alone.

Payments continue to be the biggest driver of adoption, with the total value of open banking-enabled payments reaching 29.89 million in July. OBL also notes that Variable Recurring Payments (VRPs) are also gaining momentum, accounting for over 4% of all open banking transactions.

Africa: Nikulipe publishes Payments Guide: Africa 2025

On 1 September 2025, Fintech company Nikulipe released the ‘Nikulipe Payments Guide: Africa 2025’ (email registration required), a report which explores the continent’s fast-growing digital economy and its implications for global merchants and payment service providers.

The guide outlines Africa’s key growth pillars, including mobile money platforms such as MTN MoMo and Airtel Money, which serve tens of millions of users. It also compares consumer payment preferences in Africa and Europe and identifies the main entry barriers. The report also provides strategic recommendations to help businesses navigate these challenges, positioning Africa as a major market for fintech innovation and digital commerce.

Authored by Charles Elliott, Virginia Montgomery and Nicole Ahlawat.

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