MR22/1.4: Competitive constraints in card payment systems call for evidence MR22/1.5: Approach to profitability analysis working paper Innovate Finance response to the PSR call for evidence and working paper

6th April 2023 | consultation

About Innovate Finance

Innovate Finance is the independent industry body that represents and advances the global FinTech community in the UK. Innovate Finance's mission is to accelerate the UK's leading role in the financial services sector by directly supporting the next generation of technology-led innovators.

The UK FinTech sector encompasses businesses from seed-stage start-ups to global financial institutions, illustrating the change that is occurring across the financial services industry. Since its inception following the Global Financial Crisis of 2008, FinTech has been synonymous with delivering transparency, innovation, and inclusivity to financial services. As well as creating new businesses and new jobs, it has fundamentally changed the way in which consumers and businesses are able to access finance.


Introduction and key points

Innovate Finance welcomes the opportunity to respond to PSR MR 22/1.4 and 1.5.

In preparing this response, we have consulted with our FinTech start-up and scale-up members that span the issuer and acquirer sides of the discussion. All members are aligned that there is an urgent need to explore constraints on competition and innovation in card payment systems.

Given the competition law considerations around sharing commercially sensitive data, we recommend that the PSR engages bilaterally with our members and the wider FinTech ecosystem.

For transparency, we recommend that the PSR sets out publicly how it intends to engage with a diverse cross-section of industry players to explore these issues in detail.

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