HMT Payment Landscape Review - Which? response

Summary

​​​​Which? welcomes HM Treasury’s review of the payment landscape. A robust, comprehensive landscape is essential to achieve the stated aim to ensure end users benefit to the fullest extent from the payments network.

Despite best efforts, it is clear that regulation has not kept pace with innovation and that certain changes to the wider payments landscape are needed in order to meet the Government's stated aim.

In particular:

• Legislative changes are necessary in order to better equip the regulator to protect consumers from authorised push payment fraud.
• Gaps that have emerged within Section 75 card protection need to be addressed. These include purchases via third party payment processors and purchases made by secondary cardholders that are not currently covered.
• Further clarity is needed over the FCA’s regulatory perimeter, specifically for emerging product classes that look and function like payment methods such as Buy Now Pay Later schemes.
• A strong regulator is needed with appropriate powers and resources to address ongoing concerns within the market, specifically in relation to card schemes and cash.