Retail Payments Infrastructure Board (RPIB) consultation on the Design of the Future Retail Payments Infrastructure - Which? response

Our main recommendations for the RPIB:

• Prioritize public needs through strategic central direction: The Future of Payments review and the National Payments Vision (NPV) identified that reliance on industry consensus to deliver payments innovations had resulted in regulatory congestion and delivery paralysis, and that greater central direction was required to coordinate activity. The Bank of England must provide this strategic direction via its leadership of the Retail Payments Infrastructure Board (RPIB) and in so doing it must ensure infrastructure design prioritizes public policy and societal needs over commercial interests. 
• Ensure consumer needs drive RPIB decisions: Current efforts to capture the consumer interest in development of the new payments infrastructure fall short and threaten to undermine the NPV’s core ambition to ensure consumers have a choice of payment methods that meet their needs. The RPIB must demonstrate that its actions will deliver what consumers want and need from payments. 
• Embed financial inclusion by design: While payments currently work well for most, the advent of a new retail payments infrastructure presents a once-in-a-generation opportunity to build a system that works for everyone, including those currently excluded or underserved. Experience confirms it is unrealistic to expect commercial firms to deliver these financial inclusion objectives of their own volition. Financial inclusion must therefore be established as a standalone design principle, backed by a clear regulatory mandate. Adding this explicit principle will ensure the infrastructure is built from the ground up to facilitate accessible payment options for all. 
• Build security into the system’s core to prevent fraud: We need a step-change in fraud prevention. The new core infrastructure should offer built-in fraud prevention across all payment methods, featuring capabilities such as enriched messaging standards for real-time risk signaling, universal access to fraud analytics for all payment firms, and improved traceability and coordination mechanisms to detect, prevent, and reverse fraudulent transactions. 
• Design future-facing features with built-in safeguards: Agentic, programmable, and delegated payments offer a range of potentially useful features for consumers. To ensure they deliver on their promise, they must include effective consumer safeguards and provide simple, customizable tools to empower consumers and allow them to retain control over their finances. 
• Design the core infrastructure to enable future consumer protections: Ensure the infrastructure acts as the foundational platform, providing the necessary functional building blocks to facilitate robust protections. This ensures that future scheme rules and governance can implement safeguards from day one, rather than attempting costly, reactive retrofits later. This approach also helps to foster the consumer confidence necessary for adoption of new payment methods. 
• Match the reliability of cash: Reliability of digital payment methods must match that of cash; the RPIB must demonstrate how digital methods will withstand extreme technical failures, cyber-attacks, and connectivity outages.