Part 4: Challenges, Friction Points, and the Regulatory Landscape
Variable Recurring Payments (VRP) are emerging as an important development in the UK payments industry, offering a new way for consumers and businesses to manage recurring transactions. Built on Open Banking infrastructure, VRP allows customers to authorise approved payment providers to initiate multiple payments within agreed limits, rather than setting up a traditional payment instruction for every transaction.
The potential benefits are significant. Merchants could gain greater flexibility over payment collection, consumers could have more control over their finances, and financial technology providers could develop new services around automated payments. However, the transition from Direct Debit to VRP is unlikely to be straightforward.
Regulatory uncertainty, inconsistent commercial arrangements, technical integration costs and established consumer habits all present obstacles. Understanding these challenges is essential for banks, merchants and fintech professionals assessing whether VRP can become a mainstream alternative to traditional recurring payments.
Regulatory Milestones and the CMA Mandate
The Legacy of the Competition and Markets Authority Mandate
The UK's progress towards Open Banking began with the Competition and Markets Authority (CMA) investigation into retail banking. Its remedies required the nine largest current account providers, commonly known as the CMA9, to implement Open Banking capabilities through standardised APIs.
The objective was to increase competition, improve consumer choice and enable authorised third-party providers to access banking information and initiate payments securely, with customer consent.
This regulatory intervention established much of the technical foundation on which Open Banking payments now operate. It enabled third-party providers to develop services that could connect directly to bank accounts, reducing reliance on card networks and other traditional payment intermediaries.
However, the original CMA mandate did not automatically establish a comprehensive commercial framework for every type of Variable Recurring Payment. Early VRP capabilities focused primarily on sweeping, which involves moving money between accounts belonging to the same person, such as transferring funds from a current account into a savings account.
Sweeping demonstrated that automated payments could operate through Open Banking with appropriate permissions and safeguards. Nevertheless, its relatively narrow use case did not resolve the broader commercial questions surrounding payments to energy suppliers, subscription services, insurers and other merchants.
For these applications, commonly described as non-sweeping VRP, providers need clear agreements covering pricing, liability, customer protection, operational responsibilities and service availability.
The distinction is important: regulatory support for Open Banking infrastructure does not, by itself, guarantee that every bank will offer commercially viable VRP services to every merchant.
The Role of JROC and Open Banking Limited
The Joint Regulatory Oversight Committee (JROC) was established to help coordinate the development of the UK's Open Banking ecosystem. It brought together the CMA, the Financial Conduct Authority (FCA), the Payment Systems Regulator (PSR) and HM Treasury to support the next phase of development.
JROC's work has focused on establishing the foundations for a sustainable future framework, including the development of commercial VRP arrangements beyond sweeping.
Open Banking Limited (OBL), which has supported the implementation and development of Open Banking standards, has played an important role in facilitating technical consistency and industry coordination. Common standards are particularly valuable because payment providers must connect with multiple banks without developing an entirely different integration for every institution.
Nevertheless, regulatory coordination and technical standardisation are only part of the solution. A viable market also requires banks and payment providers to agree on commercial terms, service levels and responsibilities.
For non-sweeping VRP to scale, participants need confidence that the service will be dependable, appropriately priced and supported by clear consumer safeguards. Progress therefore depends on both regulatory direction and practical cooperation between financial institutions, merchants and payment service providers.
The wider regulatory landscape also matters. The UK's future payments framework, including the development of an appropriate long-term regulatory and commercial model for Open Banking, will influence investment decisions. Banks need sufficient certainty to justify infrastructure spending, while merchants need confidence that VRP will remain accessible and economically attractive over the long term.
Related Articles :
- Part 1 Variable Recurring Payments (VRP): The Impending Replacement for Direct Debits?
- Part 2 Variable Recurring Payments (VRP): The Impending Replacement for Direct Debits?
- Part 3 Variable Recurring Payments (VRP): The Impending Replacement for Direct Debits?
- Part 5 Variable Recurring Payments (VRP): The Impending Replacement for Direct Debits?