The Payments Newsletter including Digital Assets & Blockchain, April 2025

In this Newsletter:

• European Accessibility Act: June 2025 compliance deadline approaching
• 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

European Accessibility Act: June 2025 compliance deadline approaching

There are over 80 million people with disabilities in the EU. The European Accessibility Act 2019 (EAA) (Directive (EU) 2019/882) implements the UN Convention on the Rights of Persons with Disabilities (UNCRPD) and aims at providing greater accessibility to everyday goods and services. It is applicable in member states from 28 June 2025.

In-scope firms – which include banks, payment service providers and e-money providers - will need to ensure that they design their websites, mobile apps, contracts and all forms of communication with consumers in a way that is accessible to persons with disabilities. This includes call centre services as well as devices such as payment terminals and ATMs.

An important point for cross-border firms to be aware of is that the EAA requirements apply according to the location of the customer, not the firm. 

This Our Thinking article looks at what in-scope financial services providers and related firms must do to ensure compliance with the EAA, as well as the limited exemptions that might apply.

Our Europe-wide regulatory team can help you with the process of mapping/gap analysis to ensure compliance with the EAA, including any required uplift in your current approach to accessibility

Regulatory Developments: Payments

Somalia: First nationwide instant payment system goes live

On 26 March 2025, the Central Bank of Somalia announced in this press release the launch of the Somalia Instant Payment System (SIPS), the country’s first nationwide instant payments infrastructure. Operated by the Somalia Payment Switch (SPS) and powered by BPC’s SmartVista platform, the system enables real-time, 24/7/365 payments and QR-based transactions under the new national standard SOMQR.

The initiative aims to reduce reliance on cash, improve interoperability between banks and mobile money operators, and expand access to digital financial services across Somalia. Key features include a participant portal for real-time transaction monitoring, a dispute resolution portal, integrated fraud management, and real-time settlement overseen by the Central Bank.

Seven banks have already connected to the system, with six more and major mobile money providers expected to join later in 2025. The infrastructure is currently cloud-based, with plans to migrate to a local data centre to enhance operational resilience.

On 26 March 2025, the Central Bank of Somalia announced in this press release the launch of the Somalia Instant Payment System (SIPS), the country’s first nationwide instant payments infrastructure. Operated by the Somalia Payment Switch (SPS) and powered by BPC’s SmartVista platform, the system enables real-time, 24/7/365 payments and QR-based transactions under the new national standard SOMQR.

The initiative aims to reduce reliance on cash, improve interoperability between banks and mobile money operators, and expand access to digital financial services across Somalia. Key features include a participant portal for real-time transaction monitoring, a dispute resolution portal, integrated fraud management, and real-time settlement overseen by the Central Bank.

Seven banks have already connected to the system, with six more and major mobile money providers expected to join later in 2025. The infrastructure is currently cloud-based, with plans to migrate to a local data centre to enhance operational resilience.

Ireland: Central Bank publishes revised Consumer Protection Code 2025

On 26 March 2025, the Central Bank of Ireland (CBI) published its revised Consumer Protection Code 2025 (CPC) following a detailed review of the existing 2012 Code. The revised Code will take effect on 24 March 2026, following a 12-month implementation period.

The revised CPC includes Standards for Business Regulations (which covers governance, resources, and risk management requirements),  the Consumer Protection Regulations (which covers, inter alia, digitalisation, informing effectively, customers facing vulnerability, advertising and complaints resolution) and specific guidance on Securing Customer’s Interests and Protecting Consumers in Vulnerable Circumstances.

The CPC will apply across all regulated sectors and includes specific provisions for banking, credit, insurance, and investment services.  These regulations govern the regulated activities of firms when dealing with customers classified as ‘consumers’. For the purposes of the CPC, consumers are defined as:

• natural persons; 
• groups of natural persons (such as clubs or charities); or 
• corporate entities with a turnover of EUR5 million or less, or part of a group with a turnover of EUR5 million or less (this threshold has been raised from EUR3 million as per the current CPC 2012). 

The existing 2012 Code will remain in effect until 24 March 2026.

See this Our Thinking article for more on this development.

India: NPCI issues addendum and new guidelines on Numeric UPI ID service

The National Payments Corporation of India (NPCI) has issued an addendum to its earlier circular introducing the Numeric UPI ID service, a system allowing users to make UPI payments using their mobile numbers as identifiers. The addendum provides further clarity on operational expectations and outlines new guidelines due to take effect from 1 April 2025.

The updated framework is designed to enhance interoperability across the UPI ecosystem and reduce risks associated with outdated or reassigned mobile numbers. Under the new rules, UPI member banks, apps, and third-party app providers (TPAPs) must regularly consult the Mobile Number Revocation List/Digital Intelligence Platform (MNRL/DIP) and update their systems at least once a week. This is intended to reduce erroneous or misdirected payments.

The guidelines also require deactivation of UPI IDs linked to dormant or recycled mobile numbers. Users whose registered mobile numbers have been inactive for extended periods may have their UPI access suspended unless they update their details with their banks. This aligns with Department of Telecommunications (DoT) rules, which allow deactivated numbers to be reassigned after 90 days of inactivity.

Additionally, NPCI is phasing out the ‘Collect Payments’ functionality on UPI to mitigate fraud risks. Going forward, pull-based UPI requests will be restricted to large, verified merchants, while person-to-person collection payments will be capped at INR 2,000.

Users who have changed or surrendered their mobile numbers without updating their bank records, or who still retain a deactivated number linked to UPI, will be required to reconfigure their UPI setup.

These developments reflect NPCI’s efforts to enhance user protection and streamline mobile-based UPI transactions as adoption continues to grow across India’s digital payments landscape.

Asia: Central banks take next step towards cross-border instant payments via Project Nexus

On 3 April 2025, five Asian central banks announced that they are one step closer to the live implementation of Project Nexus, a multilateral instant cross-border payments scheme connecting domestic instant payment systems (IPS). In a joint statement, the Bangko Sentral ng Pilipinas, Monetary Authority of Singapore, Bank Negara Malaysia, Bank of Thailand, and Reserve Bank of India confirmed the incorporation of Nexus Global Payments (NGP) to manage and operationalise the scheme.

NGP, incorporated in Singapore as a not-for-profit entity, marks the formal transition of the BIS-led initiative to real-world implementation. It will now begin the process of appointing a Nexus Technical Operator to build and run the platform.

Project Nexus is intended to support the G20 targets on cross-border payments by improving speed, cost, transparency, and accessibility. The initiative is expected to benefit overseas workers, SMEs, and regional investors by enabling seamless and affordable cross-border transactions.

New Zealand: Central bank expands Exchange Settlement Account System access and some Depositor Compensation Scheme provisions commence

On 31 March 2025, the Reserve Bank of New Zealand (RBNZ) announced that its Board has approved revised access criteria for the Exchange Settlement Account System (ESAS). The ESAS is New Zealand’s principal high-value payments and settlement system.

The changes will expand eligibility beyond registered banks and government entities, opening access in two phases: first, to licensed non-bank deposit takers (NBDTs); and second, to other qualifying entities such as payment service providers, overseas deposit takers and operators of designated financial market infrastructures.

The revised access policy follows two rounds of consultation and is aimed at supporting financial innovation while maintaining the safety and integrity of the system. Finalised criteria and application details are expected in the coming weeks.

Separately, on 1 April 2025, provisions of the Deposit Takers Act 2023 relating to the new Depositor Compensation Scheme (DCS) also came into force in accordance with the Deposit Takers Act Commencement Order 2025. These include new information-gathering powers for the RBNZ and the application of certain standards during the transition period ahead of the DCS’s full commencement on 1 July 2025.

Global: FSB launches Forum on Cross-Border Payments Data

On 27 March 2025, the Financial Stability Board (FSB) published a press release announcing the launch of a new Forum on Cross-Border Payments Data to support greater alignment and interoperability across global data frameworks.

The Forum will bring together experts in payments, AML/CTF, sanctions, and data privacy to strengthen cooperation on how cross-border payments data is collected, stored, and managed. It will also serve as a platform for dialogue, research, and information-sharing, and will engage with international bodies such as the FATF and the OECD.

The FSB also plans to establish a private sector advisory group to provide industry input. The Forum will hold its first meeting in May 2025.

United Kingdom: PSR publishes update on timings for APP scams claims management consultation

On 10 April 2025, the Payment Systems Regulator (PSR) published an update on its consultation on an authorised push payment (APP) scams reimbursement claims management system (RCMS).

Having initially planned to consult in April 2025, the PSR now anticipates being able to consult within three to six months. This is in light of stakeholder feedback on system development and delivery and the government's National Payments Vision (NPV), which includes a review of Pay.UK.

The PSR also states that the consultation:

• will not propose placing a regulatory mandate on payment service providers (PSPs) to use a particular system for managing claims or for meeting the "reporting standard B" requirements, as it is for PSPs, working with Pay.UK, to determine the best approach to meeting their regulatory obligations; and
• will request feedback on: a deadline for adopting reporting standard B by no later than December 2026; and placing any additional regulatory obligations on Pay.UK that may be necessary to enable it to most effectively meet its compliance monitoring obligations in Specific Direction 19.

In the meantime, Pay.UK will continue to monitor compliance with the Faster Payments System (FPS) reimbursement rules and the PSR will monitor compliance with its legal directions using the reporting standard A data.

The PSR states that it is also considering the impact of this change on the timing and collection of sending and receiving firm data for its APP fraud performance data work beyond 2025.

United Kingdom: APPG on Fair Banking publishes report on APP fraud

On 2 April 2025, the All-Party Parliamentary Group (APPG) on Fair Banking published a report on authorised push payment (APP) fraud, highlighting its scale and human impact in the UK.

The report assesses the mandatory reimbursement requirement (MRR), industry fraud warnings, and current reporting channels. Key recommendations include:

• requiring all payment service providers (PSPs) to provide clear fraud reporting pathways across platforms — or consider introducing a centralised reporting system;
• requiring social media companies to contribute to the MRR and Economic Crime Levy, and holding them accountable for tackling fraud;
• ensuring that the Payment Systems Regulator (PSR) monitors the use of fraud warnings to prevent misuse in denying compensation; and
• increasing transparency on APP fraud data, including:
  • number and type of APP fraud cases;
  • average number of payments per case;
  • volume of complaints to the Financial Ombudsman Service (FOS) about non-payment of compensation; and
  • compliance with the five-day reimbursement target under the MRR.

Further recommendations are expected later in 2025.

European Union: EBA report highlights key risks for consumers

On 27 March 2025, the EBA published its Consumer Trends Report for 2024/25, identifying three key risks for EU consumers: payment fraud, rising indebtedness, and de-risking. The report is based on input from EU national authorities, ombudsmen, consumer and industry groups, and the EBA’s Retail Risk Indicators.

Payment fraud remains the top concern, with a rise in scams using social engineering tactics to bypass strong customer authentication. Indebtedness has grown due to the increasing use of buy now, pay later (BNPL) and short-term credit, often offered without robust creditworthiness assessments or clear disclosures. De-risking—where consumers face barriers to opening or keeping bank accounts—was found to disproportionately affect vulnerable groups such as migrants, refugees, and those with limited financial histories.

The EBA will consider further actions in 2025 and 2026 to address these issues and strengthen consumer protection across the EU.

United States: Presidential Executive Order to phase out paper-based Treasury payments by end of 2025 is signed

On 25 March 2025, President Donald J. Trump signed an Executive Order mandating the end of paper-based federal payments by 30 September 2025. The directive requires all federal agencies to transition to electronic payment methods—such as direct deposit, prepaid cards, and digital wallets—for disbursements including tax refunds, benefits, and vendor payments.

The move is intended to enhance efficiency, reduce costs, and address the increasing risks of fraud and mail theft. Treasury data shows that paper cheques are 16 times more likely to be lost, stolen or altered than electronic payments, and maintaining cheque processing infrastructure cost over $657 million in FY2024.

Limited exceptions will apply where digital payment is not feasible—for example, for individuals without banking access, certain emergency payments, and in connection with national security or law enforcement operations. Treasury will work with consumer groups and financial institutions to support access for the unbanked and underbanked.

Agencies must submit transition plans within 90 days, and Treasury will launch a public awareness campaign. An implementation report will be submitted to the White House later this year.

United Kingdom: FCA updates guidance on cash-based money laundering and announces multi-firm review

On 2 April 2025, the FCA updated its webpage on cash-based money laundering and announced a multi-firm review in 2025/26 to assess related financial crime risks.

Among other things, the FCA:

• highlights its regime to protect access to cash which came into effect in September 2024;
• reaffirms its focus on financial crime in its 2025–2030 Strategy (see the separate item on this);
• reiterates expectations of banks in relation to measures it introduced to prevent money laundering via the Post Office; and
• confirms the review will cover the Post Office and other cash entry points into the financial system.

United Kingdom: FCA publishes five-year strategy and feedback statement on Consumer Duty rule review

On 25 March 2025, the FCA published its 2025–2030 Strategy, setting out four priorities: being a smarter regulator, supporting economic growth, helping consumers navigate financial decisions, and fighting financial crime. The Strategy reflects the FCA’s evolving role in promoting innovation and international competitiveness.

Alongside the Strategy the FCA issued a feedback statement, FG25/2, to its July 2024 call for input on its Consumer Duty rule review. The FCA will not pursue a wholesale Handbook review but has outlined targeted areas for simplification, with a renewed focus on outcomes-based regulation. This includes its work on reviewing the contactless payments limit, on which it recently published an engagement paper (see the March edition of this Newsletter).

See this Our Thinking article for more on the FCA's Strategy and this Our Thinking article for more on the FCA’s feedback statement.

United Kingdom: FCA publishes Annual Work Programme for 2025/26

On 8 April 2025, the FCA published its Annual Work Programme for 2025/26, setting out how it will deliver the four priorities from its 2025-2030 Strategy (see the above item) in the coming year.

Points of interest for payments and digital assets in the FCA’s Work Programme include the following new and ongoing work to support its Strategy’s focus on sustained UK economic growth through a more competitive, productive and innovative UK financial services industry:

• Extending its Pre-application Support Service (PASS) to all wholesale, payments and crypto firms.
• Consulting on changes to the £100 contactless limit, potentially allowing firms with strong fraud controls to set their own limits. This Our Thinking article looks at the FCA’s recent engagement paper on the contactless limit, which closes on 9 May 2025. The engagement paper was also covered in our March Newsletter.
• On Open Banking and Open Finance, using the powers expected under the Data (Use and Access) Bill to develop the regulatory framework for Open Finance, prioritising Small and Medium Enterprises (SME) lending and, as the Payment Systems Regulator (PSR) and its functions are primarily consolidated within the FCA, working with the PSR and partners to deliver the National Payments Vision (NPV), which includes a new Open Banking payment method (variable recurring payments). For more on the NPV, take a look at our article here.

This Our Thinking article considers the FCA’s Work Programme in more detail. For our thoughts on the implications of the Work Programme for digital assets and blockchain, take a look at this Our Thinking article.

United Kingdom: PRA publishes Business Plan for 2025/26

On 10 April 2025, the PRA published its Business Plan for 2025/26, setting out the workplan for each of its strategic priorities and strategy to advance its primary and secondary objectives.

The PRA comments that, alongside its continual focus on advancing its objectives of safety and soundness, policyholder protection, and competition, this year’s Business Plan reflects the evolution of its priorities, and in particular the work it is doing to deliver its new secondary objective on competitiveness and growth.

Points of interest for payments and digital assets in the Business Plan include:

• In 2025/26, the PRA will develop its proposed policy to implement the Basel Committee on Banking Supervision (BCBS) standard on banks’ cryptoassets exposures in the UK, as well as continuing to engage with international partners, including the BCBS, to assess bank-related developments in digital money and cryptoassets markets.
• The PRA has continued to contribute to the Bank of England’s work on innovation in money and payments, including through monitoring developments in deposit takers’ innovation in deposits, e-money, and stablecoins, consistent with the Dear CEO letter published in 2023. This work will continue in 2025. 

Take a look at this Our Thinking article for more on the PRA’s Business Plan.

United Kingdom: Financial Services Regulatory Initiatives Forum publishes eighth edition of Regulatory Initiatives Grid

On 14 April 2025, the Financial Services Regulatory Initiatives Forum published the eighth edition of its Regulatory Initiatives Grid setting out the regulatory pipeline over the next 24 months. Some items of interest for payments and digital assets include:

Payments

• Changes to safeguarding requirements for PIs/EMIs: Following the FCA’s September 2024 consultation, a policy statement and interim final rules are expected to be published at the end of H1 2025. Interim rules are likely to come into force during H1 2026. Timing of end-state final rules is dependent on relevant legislative changes being made by HM Treasury (HMT).
• Payment services contract termination rule changes: Legislation to be laid in H1 2025 (so Q2 2025 now).
• National Payments Vision (NPV) implementation: Q2 2025 for Bank of England (BoE), PRA, FCA and Payment Systems Regulator (PSR) Memorandum of Understanding revision; Q2 2025 for BoE and PSR to set out approach to payments infrastructure and its delivery.
• Authorised Push Payment (APP) scam prevention: The PSR will consult in Q2 2025 on the reimbursement claims management system (RCMS), although this update from the PSR on 10 April 2025 suggests the timeline could be between 3 and 6 months for publication of the consultation (see the separate item on this). A Cycle 3 APP scams report on cases that took place before reimbursement is due from the PSR in Q4 2025. An independent 12-month evaluation of the PSR’s reimbursement requirement will be published in Q2 2026.
• Payment Services Directive/E-Money Directive: HMT and the FCA will provide further information about their intended approach for consultation in due course.
• SCA repeal and replacement: As set out in the NPV, the government is committed to commencing revocation of SCA regulations in PSRs 2017. The FCA will consult on replacing rules with an outcomes-based approach. In the shorter-term, the FCA is also considering its approach to contactless payment limits, which are set out within SCA RTS. If, following its March 2025 engagement paper, the FCA decides to propose amendments to the SCA RTS, it will publish a consultation paper later in 2025.

Banking, credit and lending

• Regulation of BNPL: A government response to its October 2024 consultation and laying of SI are due in Q2 2025.

Open Banking and smart data

• Open Banking - Long-term regulatory framework: HMT is working to create a long term regulatory framework for Open Banking. An HMT consultation is planned in 2025 with an SI in Q4 2025.
• Joint Regulatory Oversight Committee: With JROC closing, the FCA is to take responsibility for delivering outstanding actions from JROC’s Open Banking roadmap. The PSR is responsible for delivering VRP Phase 1 by the end of this year. The FCA will publish a next steps document in H1 2025. The VRP product is due to go live in the market in H2 2025.
• Smart Data: Open Banking: The Data (Use and Access) Bill is expected to pass into law in Summer 2025. This will grant powers to establish a long-term regulatory framework for Open Banking and future Smart Data schemes. An SI to create a Smart Data scheme for Open Banking is likely to be laid in Q1 2026. Within a year, the FCA and HMT will publish a roadmap for the rollout of Open Finance.  They expect the regulatory foundations for the first scheme to be in place by the end of 2027.

DLT and cryptoassets

• PRA framework for prudential treatment of firms’ exposures to cryptoassets: The PRA is developing changes in relation to implementing the Basel standard.  A consultation paper is planned for Q4 2025, and a policy statement in H2 2026.
• Regulatory requirements for new cryptoasset regime: At least one discussion paper and four consultation papers are planned for this year, as per the FCA roadmap.
• Financial services regulation of cryptoassets (HMT): Draft legislation was to be published in Q1 2025 (so this may be imminent). Legislation is due to be laid in H2 2025.
• Managing the failure of systemic digital settlement asset firms: HMT continues to consider amendments to the Special Administrative Regime process. Further details on HMT’s approach will be shared in due course.
• Digital pound: The BoE and HMT are currently in the “design phase”. No decision has yet been taken on whether to launch a digital pound.
• Consultations on stablecoin regime: Discussion papers were published in November 2023. A follow-on FCA consultation paper is subject to timings of HMT secondary legislation being laid. A follow-on BoE consultation is expected in 2025.

United Kingdom: FCA publishes findings from review of firms’ treatment of customers in vulnerable circumstances involving bereavement and PoAs

On 12 April 2025, the FCA published the findings of its review of how retail banks and building societies approach the treatment of customers in vulnerable circumstances that involve bereavement and powers of attorney (PoAs).

The findings will be of particular interest to retail banks, building societies, wealth managers and some payment institutions (PIs) and e-money institutions (EMIs).

Areas in need of particular focus by firms are:

• outcomes testing and monitoring; and
• reviewing and improving potentially fragmented customer relationship management (CRM) systems across business lines/legal entities to ensure that customers in vulnerable (including bereaved) circumstances don’t have to repeat information or have their cases delayed or dropped altogether because they have been ‘lost’ in a firm’s systems.

The FCA encourages all firms across the banking, payments and insurance sectors to apply and build on the good practices observed to help consumers navigate their financial lives. It has written to all firms in its review, highlighting its findings and the expected next steps.

Whilst the review focused specifically on the treatment of customers in vulnerable circumstances involving bereavement and use of PoAs, the themes highlighted by the FCA have potential relevance to all touchpoints with customers throughout the product/service lifecycle.

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

United Kingdom: Bank of England outlines wholesale payments innovation priorities and NAO to review RTGS renewal programme

On 25 March 2025, Victoria Cleland (Executive Director, Payments) delivered a speech etting out the Bank of England’s (BoE) vision for innovating wholesale payments. The speech highlighted the BoE’s commitment to modernising infrastructure, expanding access to the Real-Time Gross Settlement (RTGS) system, promoting the adoption of ISO 20022, and enabling experimentation in areas such as synchronisation and tokenisation. The BoE also plans to launch a programme of wholesale experiments to explore future use cases for synchronisation and wholesale CBDC.

Among other developments, the BoE will mandate the use of ISO 20022 enhanced data for certain CHAPS payments from 1 May 2025 and will shortly publish updates on its access policy for non-bank payment service providers (PSPs) and financial market infrastructures (see the separate item below for subsequent developments on this).

Separately, on 27 March 2025 the National Audit Office (NAO) published a webpage announcing a study into the BoE’s RTGS renewal programme. The review, scheduled for winter 2025/26, will assess whether the BoE is managing the programme effectively and delivering a system resilient to future developments and digital transformation.

United Kingdom: Bank of England publishes response to discussion paper on reviewing access to RTGS accounts for settlement

On 8 April 2025, the Bank of England (BoE) published its response to its February 2024 discussion paper on reviewing access to Real-Time Gross Settlement (RTGS) accounts for settlement.

The discussion paper sought views on the BoE’s priority areas to further improve access to settlement in central bank money, remove unwarranted barriers, and realise the capabilities and benefits of the renewed RTGS service.

Respondents were generally supportive of the RTGS access review and were in broad agreement with the BoE's priority areas. Details of actions the BoE has taken in response to feedback to the discussion paper include the publication of:

• An updated version of its guide for non-bank payment service providers (NBPSPs) seeking direct access to UK payment systems.
• New rules on the BoE’s expectations for RTGS participants.
• A revised version of its RTGS access policy, consolidating previous access policies for RTGS settlement accounts, settlement services and omnibus accounts.

Stage gates have also been introduced (as set out in the revised RTGS access policy) to enable applicants seeking access to RTGS, including new and small financial market infrastructures (FMIs), to build internal capacity and confidence before launching their services externally. This is to allow applicants to test connectivity and grow their business in a controlled way subject to restrictions to mitigate risk.

The BoE also summarises its future work on:

• providing safeguarding facilities directly to NBPSPs;
• supporting the FCA and HM Treasury on reforming the broader NBPSP regulatory framework to facilitate direct access to RTGS; and
• engaging further with industry on the CHAPS direct participation threshold review.

United Kingdom: PRA consults on FSCS deposit protection limit increase and implementation of Bank Resolution (Recapitalisation) Bill

On 31 March 2025, the PRA published a consultation paper (CP4/25) proposing to raise the Financial Services Compensation Scheme (FSCS) deposit protection limit from £85,000 to £110,000 and to increase the temporary high balance (THB) limit from £1 million to £1.4 million. Both changes would take effect from 1 December 2025. The PRA emphasises the importance of firms preparing themselves now for the potential change by ensuring they can quickly adjust their single customer view (SCV) systems and that contact details held within the SCV are up to date. The PRA is also proposing changes to disclosure requirements, with a transitional period until 31 May 2026 for firms to update disclosure materials.

In addition, the PRA is consulting on new and amended rules to enable the FSCS to fulfil its new functions under the Bank Resolution (Recapitalisation) Bill which is currently before Parliament.

For further details, see this Our Thinking article.

European Union: EBA publishes report on peer review of performance of DGS stress tests

On 7 April 2025, the EBA published a eport on the results of a peer review of the performance of stress tests by deposit guarantee schemes (DGSs).

The EBA found that all of the DGSs assessed had effectively developed their stress testing programmes in line with the methodology outlined in its guidelines on DGS stress testing (EBA/GL/2021/10), with only minor shortcomings. However, among other things it noted that not all of the DGSs could fully demonstrate that they had performed all the mandatory core stress tests using realistic assumptions and conducting objective evaluations or that they had increased the severity and complexity of their testing scenarios to adequately stress test their ability to intervene.

In the report, the EBA sets out best practices for all EU DGSs on issues including mandatory core stress tests, co-operation arrangements and the severity and complexity of testing scenarios. It intends to conduct a follow-up peer review of the implementation of the measures included in the report in two years.

United Kingdom: PSR consults on proposed remedies for Mastercard and Visa scheme and processing fees

On 2 April 2025, the Payment Systems Regulator (PSR) published a consultation paper (CP25/1) on proposed remedies to address issues identified in its March 2025 final report on its market review into card scheme and processing fees.

The PSR is proposing to:

• require Visa and Mastercard to publish more detailed information about scheme and processing fees, helping acquirers and merchants better understand the charges and ultimately reduce costs;
• introduce regulatory financial reporting to enable the PSR to effectively monitor and assess the schemes’ UK financial performance;
• improve pricing governance by requiring clearer decision-making processes, record keeping, and named senior accountability for pricing decisions; and
• require the publication of financial and performance data to enhance transparency and accountability.

The consultation closes on 28 May 2025. If the PSR decides to proceed, it will consult again on a specific remedy package. This will include a cost benefit analysis and a draft direction.

Regulatory Developments: Digital Assets

United States: SEC Crypto Task Force announces next roundtables on crypto regulation

On 25 March 2025, the Securities and Exchange Commission’s (SEC) Crypto Task Force announced the next dates in its roundtable series on crypto regulation. Topics include trading, custody, tokenisation, and DeFi. Recordings of each roundtable will be posted on SEC.gov afterwards.

United States: SEC says ‘covered’ stablecoins are not securities

On 4 April 2025, the Securities and Exchange Commission’s (SEC) Division of Corporate Finance issued a statement confirming that “covered stablecoins” — those designed and marketed primarily for payments, money transmission, or storing value — are generally not securities and do not require SEC registration.

The SEC noted that these stablecoins are typically pegged to the USD and backed by low-risk, liquid assets. However, it clarified that the view is not dispositive, and any determination will depend on the facts of a specific offering.

The announcement comes as Congress continues to advance stablecoin legislation, including the STABLE Act in the House and the GENIUS Act in the Senate.

United States: FDIC removes prior approval requirement for crypto activities

On 28 March 2025, the Federal Deposit Insurance Corporation (FDIC) issued a new Financial Institution Letter (FIL-7-2025), clarifying that FDIC-supervised institutions no longer need to obtain prior FDIC approval before engaging in permissible cryptoasset-related activities. This guidance replaces FIL-16-2022 and reflects a shift towards a more flexible, risk-based approach.

Further guidance is expected to follow to support banks engaging in crypto- and blockchain-related activities within safety and soundness standards.

This aligns with a similar development from the Office of the Comptroller of the Currency (OCC). As covered in our March Newsletter, on 7 March 2025 the OCC issued Interpretive Letter 1183, rescinding prior guidance that required supervisory non-objection before engaging in crypto custody, stablecoin, and distributed ledger activities.

United States: CFTC aligns digital asset derivatives with broader derivatives regime

On 28 March 2025, the Commodity Futures Trading Commission (CFTC) announced the withdrawal of two staff advisories to confirm that digital asset derivatives will be subject to the same regulatory framework as other derivatives products.

Through CFTC Letters No. 25-08 and 25-07, the agency’s Divisions of Clearing and Risk and Market Oversight withdrew guidance from 2023 and 2018, respectively, which had applied heightened scrutiny to the listing and clearing of crypto-related derivatives. The CFTC stated that these withdrawals reflect growing market maturity and staff experience, and are intended to avoid any implication that digital asset derivatives will be treated differently under the Commodity Exchange Act.

According to the agency, this step supports consistency in oversight while still promoting responsible innovation and managing systemic risk. The announcement coincided with similar moves by the FDIC and OCC, as outlined above, to ease procedural burdens on crypto-related activities for banks.

United States: President signs Ways and Means resolution overturning IRS “DeFi Broker rule”

On 10 April 2025, President Donald J. Trump signed into law H.J.Res.25, a Congressional Review Act disapproval resolution led by Ways and Means Committee Republican Mike Carey (OH-15). The rule would have submitted “DeFi Brokers” to the same reporting rules as securities brokers and operators of custodial digital asset trading platforms. For more information, see the related press release and factsheet.

Japan: Financial Services Agency publishes discussion paper on cryptoasset regulatory framework

On 10 April 2025, the Japanese Financial Services Agency (FSA) published a (in Japanese) on a cryptoasset regulatory framework which reportedly proposes to categorise cryptoassets into two distinct types:

• Funding/Business Cryptoassets, which includes assets created for fundraising purposes, with the capital raised being directed towards various projects; and
• Non-Fundraising/Non-Business Cryptoassets, which refers to assets that do not function as fundraising tools or business assets (e.g. bitcoin).

United Arab Emirates: Central bank to launch Digital Dirham for retail use by end of 2025

The Central Bank of the UAE (CBUAE) has confirmed that its central bank digital currency (CBDC), the Digital Dirham, will be launched for retail use in the final quarter of 2025. The announcement was made in an official press release issued by the CBUAE on 27 March 2025, which also unveiled a new symbol for the dirham as part of a broader rebranding initiative.

According to the CBUAE, the Digital Dirham will be distributed via authorised banks, exchange houses, finance companies, and fintech firms. It will operate alongside physical cash and be accepted across all payment channels. The CBDC is designed to support tokenisation, smart contracts, and enhanced security features, enabling instant settlements and more complex transaction types.

The launch forms part of the CBUAE’s Financial Infrastructure Transformation (FIT) Programme and is underpinned by Federal Decree-Law No. (54) of 2023, which legally recognises the Digital Dirham as legal tender. A dedicated platform and digital wallet system have also been developed to support retail, wholesale, and cross-border use cases.

This development aligns with the UAE’s ambition to strengthen its position as a global financial hub. The CBUAE’s accession to the FX Global Code — becoming the first central bank in the Arab region to join — further reflects its commitment to improving transparency and governance in the foreign exchange market.

United Kingdom: Bank of England publishes updates on its Digital Pound work

On 10 April 2025, the Bank of England (BoE) issued a number of publications on its Digital Pound work.

Launch of Digital Pound Lab

As already planned and confirmed in its January 2025 progress update (see our article here), the BoE has published a new webpage announcing the imminent launch of the Digital Pound Lab. The Lab will provide a simulated environment to test the potential capabilities of a digital pound.

The Lab is expected to run from August 2025 to July 2026 in two phases. Applications are open to all private and public sector companies and organisations from technology, payments, banking, retail and other relevant sectors that are interested in hands-on experimentation with Digital Pound use cases. Firms may apply for both phases.  

The Terms of Participation and details on how to apply, as well as the criteria on which applications will be assessed, have also been published. There is a BoE webinar on the Lab on 23 April 2025.

Design note – Intermediary roles and scheme rulebook

The BoE has also published a design note which focuses on a subsection of the Scheme and Regulation pillar of the proposed Digital Pound Blueprint (see our article on the previously published Blueprint Framework design note here) – the potential role of intermediaries in a Digital Pound Ecosystem.

The BoE anticipates that, in addition to any legislative and regulatory requirements that would apply to Payment Interface Providers (PIPs) and External Service Interface Providers (ESIPs), it may be necessary to set out additional requirements in a 'scheme rulebook' or similar document in place between the BoE and intermediaries. The design note focuses specifically on the ‘scheme rulebook’. The BoE welcomes feedback via email to CBDC@bankofengland.co.uk.

Digital Pound experiment report: Offline payments

In addition, the BoE has published an offline payments report. A project was undertaken to assess the technical feasibility of implementing an offline payment functionality for a digital pound. The detail of the findings from the project can be found on the BoE webpage for the report (linked above).

The BoE’s policy work on offline digital pound payments is ongoing. It expects to conduct a policy assessment to determine what the findings might mean for a digital pound. No final decision has been made on whether an offline payment functionality would be implemented if a digital pound were launched. The project explored offline payments from a technology perspective only. There are other technical challenges and other factors, such as policy, operational, legal and commercial considerations, that will impact the design choices for offline payments.

Taiwan: Financial Supervisory Commission releases draft Virtual Asset Service Act outlining crypto regulations

On 25 March 2025, Taiwan’s Financial Supervisory Commission (FSC) announced in this press release the draft of a Virtual Asset Service Act, setting out a proposed framework for regulating crypto service providers and stablecoin issuers. While the FSC has summarised the key provisions, the full text has not yet been published and is expected to follow shortly on its website.

The draft law would introduce licensing requirements for virtual asset service providers (VASPs), including rules on capital, governance, internal controls, and personnel qualifications. It also proposes that banks may issue fiat-backed stablecoins pegged to the New Taiwan Dollar, subject to FSC approval.

The FSC would gain powers to inspect firms, enforce compliance, and impose penalties. The draft includes provisions to prevent fraud, protect customer assets, and require annual risk assessments, inline with Taiwan’s updated anti-money laundering regime, which took effect in January 2025.

A 60-day public consultation is now open, with the FSC aiming to finalise and submit the law to the Executive Yuan by the end of June 2025. The draft forms part of a broader push to promote responsible innovation, alongside initiatives such as a crypto custody pilot and approval of foreign crypto ETFs for professional investors.

Australia: Treasury releases digital assets white paper outlining regulatory framework and pilot trials

On 21 March 2025, the Australian Treasury published a white paper setting out a whole-of-government strategy for regulating and integrating digital assets into the national economy. Drawing on regulatory models from the EU and Singapore, the plan outlines a phased framework for tokenisation, digital asset licensing, and wholesale central bank digital currency (CBDC) exploration.

The white paper confirms that the government will not pursue a retail CBDC at this time, but will prioritise pilot programmes involving tokenised money — including stablecoins —for settlement in wholesale markets. These trials will be led by the Treasury, the Reserve Bank of Australia, and the Australian Securities and Investments Commission (ASIC).

To support market development, the government will introduce a new licensing regime for crypto exchanges, referred to as Digital Asset Platforms (DAPs). DAP operators will be subject to financial services obligations including capital, custody, and disclosure requirements, with mandatory use of third-party custodians to safeguard customer assets.

The white paper also signals a commitment to address de-banking concerns, highlighting that the new DAP framework is intended to provide regulated pathways for financial institutions to engage with digital asset firms.

European Union: Summary of recent MiCA developments

The following regulatory and supervisory materials supplementing the Markets in Crypto-Assets Regulation ((EU) 2023/1114) (MiCA) have been published recently:

• On 24 March 2025, four Delegated Regulations were published in the Official Journal of the EU and they entered into force on 13 April 2025:
  • Delegated Regulation (EU) 2025/415: Sets out regulatory technical standards (RTS) for adjusting own funds requirements and establishing the minimum features of stress testing programmes for issuers of asset-referenced tokens (ARTs) and of e-money tokens (EMTs). This includes scenarios, frequency, and documentation obligations to ensure that issuers can meet redemption and reserve requirements under stress.
  • Regulation (EU) 2025/418: Specifies the minimum content of governance arrangements relating to the remuneration policies of issuers of significant ARTs or EMTs. It covers criteria such as performance-based remuneration structures, risk alignment, and internal oversight mechanisms.
  • Delegated Regulation (EU) 2025/419: Provides the procedure and timeline for issuers of ARTs or EMTs to adjust their own funds levels in line with risk exposures or changes in significance status, as required under Article 45(7) of MiCA.
  • Delegated Regulation (EU) 2025/421: Establishes RTS on the data to be provided for classification of cryptoasset white papers, including specifications to ensure the information is structured, standardised, and machine-readable.

• On 26 March 2025, the EBA published official translations of its guidelines (EBA/GL/2024/16) on templates to support competent authorities in supervising issuer compliance under Titles III and IV of MiCA. The guidelines apply from 26 May 2025 and specify templates for information reporting by issuers of ARTs and EMTs, including data collection from relevant cryptoasset service providers (CASPs). National competent authorities (NCAs) must notify the EBA by the same date as to whether they comply with the guidelines.
• Also on 26 March 2025, ESMA published official translations of its guidelines (ESMA35-1872330276-2031) under Article 81(15) MiCA. These outline requirements for assessing client suitability and the format of periodic statements for crypto portfolio management. The guidelines apply from 25 May 2025. NCAs must notify ESMA by this date as to whether they intend to comply.
• On 31 March 2025, six additional MiCA-related regulations were published in the Official Journal and will enter into force on 20 April 2025:
  • Commission Delegated Regulation (EU) 2025/300: Sets out RTS on the information to be exchanged between NCAs to support effective cross-border supervision under Article 95(10) MiCA.
  • Commission Delegated Regulation (EU) 2025/305 and Commission Implementing Regulation (EU) 2025/306: Provide, respectively, RTS and implementing technical standards (ITS) on the authorisation process for cryptoasset service providers (CASPs) under Articles 62(5) and 62(6) MiCA. These define the required content, format, and procedures for CASP licence applications, including operational, governance, and financial information.
  • Commission Delegated Regulation (EU) 2025/413> and Commission Delegated Regulation (EU) 2025/414: Set out RTS under Articles 42(4) and 84(4) MiCA on the information required to assess proposed acquisitions of qualifying holdings in issuers of ARTs and CASPs respectively. The standards aim to ensure transparency in ownership changes and consistency in prudential evaluations.
  •  Delegated Regulation (EU) 2025/422: Establishes RTS on sustainability-related disclosures for CASPs and token issuers, pursuant to Articles 6(12), 19(11), 51(15), and 66(6) MiCA. These detail the format and methodology for disclosing sustainability indicators and their impact on the climate and environment.
•  On 7 April 2025, ESMA published Q&As on:
  • Registered AIFMs and application of article 60(5) of MiCA; and
  • "copy trading services/auto trading services" related to cryptoassets and scope of services under MiCA.

European Union: EIOPA recommends 100% capital charge for (re)insurers’ cryptoasset holdings

On 27 March 2025, EIOPA published its technical advice to the European Commission recommending a 100% capital requirement for all cryptoasset holdings of EU (re)insurers. It argues that current capital treatments underestimate crypto risks and that a one-to-one charge offers a simple, harmonised interim approach.

The advice follows the Commission’s Call for Adviceand forms part of the Solvency II Level 2 review. EIOPA notes that a more nuanced framework may be needed as market adoption evolves but considers the blanket charge appropriate for now.

European Union: EBA publishes draft technical package for reporting framework v4.1

On 27 March 2025, the EBA published a draft technical packagefor version 4.1 of its supervisory reporting framework. The package includes standard specifications—validation rules, the Data Point Model (DPM), and XBRL taxonomies—intended to support early implementation by reporting entities ahead of the final release, expected by the end of May 2025.

The draft supports the following reporting areas:

• Pillar 3 templates under the comprehensive implementing technical standards (ITS) on Pillar 3 disclosures, for integration into the Pillar 3 data hub.
• Reporting obligations introduced by the MiCA reporting guidelines, which are the EBA’s own-initiative guidelines for supervisory and significance assessment purposes under MiCA.
• Integration of the ITS on instant payments into the DPM and taxonomy.
• Additional validation rules added to the ESG ad-hoc data collection module.

This release continues the transition to DPM 2.0, as set out in the EBA’s June 2024 roadmap, and includes the data dictionary in both DPM 1.0 and DPM 2.0 formats. The EBA invited stakeholders to submit feedback on the draft technical package by 15 April 2025, and comments on the DPM 2.0 glossary may be submitted on a rolling basis until the revision is finalised.

United Kingdom: HM Treasury issues policy paper on pilot Digital Gilt Instrument (DIGIT)

On 18 March 2025, HM Treasury and the UK Debt Management Office (DMO) published a policy paper outlining plans for a pilot Digital Gilt Instrument (DIGIT), a short-dated, transferable UK government security to be issued and held on a distributed ledger technology (DLT) platform.

The DIGIT issuance will take place within the Digital Securities Sandbox (DSS) and operate independently from standard debt issuance. It aims to test end-to-end digital sovereign debt issuance and promote DLT adoption in UK capital markets.

HM Treasury and the DMO invited feedback from investors and DLT providers on design preferences, platform capabilities, and operational requirements by 13 April 2025. Responses will help to shape the procurement strategy, with supplier selection expected by late summer 2025.

Hong Kong: SFC issues new staking guidance for VATPs and virtual asset funds

On 7 April 2025, the Hong Kong Securities and Futures Commission (SFC) announced new guidance allowing licensed virtual asset trading platforms (VATPs) and SFC-authorised virtual asset funds (VA Funds) to engage in staking under defined conditions.

The SFC circular to VATPs sets out operational and risk management standards for platforms offering staking services. These include safeguarding client assets, maintaining control over withdrawal mechanisms, managing validator-related risks, and ensuring transparency about fees, lock-up periods, and potential losses (e.g. from slashing, bugs, or validator inactivity). Licensed VATPs must obtain the SFC’s prior written approval and will be subject to specific licence conditions.

Separately, the SFC revised its circular for SFC-authorised funds to permit eligible VA Funds to participate in staking activities. Such funds may only stake via licensed VATPs or authorised institutions and must comply with a cap to manage liquidity risk. Prior SFC consultation and approval are required before any staking or virtual asset-related activities commence.

Both circulars form part of the SFC’s broader strategy to expand the virtual asset ecosystem under its “ASPIRe” roadmap, balancing innovation with robust investor protection.

Singapore: MAS consults on prudential treatment of cryptoasset exposures and capital instrument requirements

On 27 March 2025, the Monetary Authority of Singapore (MAS) published a consultation on proposed amendments to banking standards relating to cryptoasset exposures and the treatment of additional Tier 1 and Tier 2 capital instruments.

The proposals aim to implement the Basel Committee on Banking Supervision’s (BCBS) standards on the prudential treatment and disclosure of cryptoasset exposures. MAS is seeking feedback on amendments to:

• the regulatory framework for capital and large exposures applicable to Singapore-incorporated banks; and
• the regulatory framework for liquidity applicable to all banks in Singapore.

The consultation closes on 28 April 2025. 

Market Developments

United States: Viamericas launches cash-to-cash money transfer service

On 24 March 2025, it was reported that Viamericas has launched a domestic cash-to-cash money transfer service. This new system is designed to address a range of customer needs including urgent expenses, cash emergencies, and other essential expenses.

To send cash, customers can visit any Viamericas agent location in the country. Recipients are then able to collect the cash from a local Viamericas agent near them. This service offers a convenient alternative for individuals without access to traditional banking services as well as those who prefer the immediacy of cash pickups.

Sweden: Trustly becomes the payment provider of the Swedish Central Bank

On 20 March 2025, it was reported that Trustly, a pay-by-bank provider, will support RIX INST, the instant settlement system of the Swedish Central Bank. Through this, Trustly will become the first third-party provider to enable instant payments through the platform. This integration will allow businesses and merchants to instantly process refunds and payments to customers of multiple Swedish banks, including ICA Banken, Länsförsäkringar, and Skandiabanken, without requiring API changes. Trustly aims to enhance speed, security and reliability in the Swedish payments ecosystem.

United Kingdom: Monzo introduces split payments

On 24 March 2025, it was reported that Monzo has introduced a split payments service, Monzo Split. This service is designed for both recurring payments, such as household bills, and one-off costs, including group dinners or social outings.

With Monzo Split, users can set up shared expenses, invite others to participate, add charges from different accounts and cards, and send reminders to help ensure that everyone contributes on time.

Global: Stripe expands collaboration with Tencent to enable in-person transactions in 20 countries

On 16 April 2025, it was reported that Stripe has expanded its long-standing collaboration with Tencent by introducing Tencent’s digital wallet, Weixin Pay, (known internationally as WeChat Pay) to Stripe Terminal, thereby enabling in-person transactions in 20 countries including Australia, Canada, France, Germany, Italy, Singapore, the United Kingdom and the United States.

Before this development – which is aimed at capturing demand among the Chinese diaspora - Weixin Pay was only available through Stripe’s online payment offerings. Now, Stripe-supported businesses also have the option to accept Weixin Pay in physical retail locations.

United Kingdom: Metro Bank launches AI scam detection tool

On 6 April 2025, Metro Bank published a press release announcing that it has launched an AI scam detection tool that allows customers to instantly check whether they are at risk of a scam or fraudulent behaviour. Customers can submit a photo or screenshot of any email, website, letter, or leaflet they are unsure about, using WhatsApp to access the service. The AI Scam Checker then analyses the content, determines whether it is likely to be fraudulent, and offers practical guidance on next steps.

Greece: The Greek Church plans digital bank launch

On 2 April 2025, it was reported that the Greek Church has applied for a banking licence with the intention of launching its own digital bank. According to sources involved in the project, the Church aims to create a fully digital financial institution, offering services accessible via smartphones and other digital devices. The same sources confirmed that church assets will not be used as collateral for the bank. If approved, the initiative includes plans to expand operations internationally, with a focus on serving the Greek diaspora.

Brazil: Central bank to add instalment feature to Pix

On 3 April 2025, it was reported that Brazil's central bank plans to introduce an instalment payment feature to its instant payments platform, Pix. The new service, called Pix Parcelado, is scheduled to launch in September this year. The feature will allow consumers to split payments into instalments, while merchants will receive the full transaction amount upfront. Pix Parcelado will be available for both consumers and businesses. The central bank has not yet released any further information regarding the technical details or cost specifications.

European Union: ECB calls for EU to develop its own payment system

On 5 April 2025, it was reported that European Central Bank (ECB) President Christine Lagarde has called for Europe to develop its own digital payments solution to end reliance on foreign digital payment infrastructure such as PayPal, Visa, MasterCard and Alipay.

United States: World Liberty Financial launches stablecoin

On 25 March 2025, it was reported that World Liberty Financial, a decentralised finance company backed by the Trump family, plans to launch a new stablecoin named USD1. USD1 will be redeemable on a 1:1 basis with the U.S. dollar and will be backed by short-term U.S. government treasuries, dollar deposits, and other cash equivalents. According to the announcement, USD1 reserves will be held in custody by BitGo. The stablecoin will initially be issued on the Ethereum and Binance Smart Chain blockchains, with future plans to expand to additional protocols.

India: Axis Bank and JP Morgan launch blockchain-based 24/7 cross-border payments

On 28 March 2025, it was reported that Axis Bank has become the first Indian financial institution to offer near-real time, 24/7 programmable USD clearing for its commercial clients through JP Morgan's digital assets unit, Kinexys. Kinexys Digital Payments (KDP) will power this development, leveraging their blockchain accounts created in 2019. With KDP, Axis Bank can now provide its commercial clients with the ability to make cross-border USD payments at any time. Reportedly, this is the first time that an Indian company will be able to receive dollar payments on a 24/7 basis.

Europe: Kraken and Mastercard plan to launch crypto debit cards

On 9 April 2025, it was reported that Kraken and Mastercard have partnered to launch both physical and digital crypto debit cards. These cards will enable users to make payments using cryptocurrencies and stablecoins at any locations where Mastercard is accepted. The initiative builds on Kraken’s recently launched payment platform, Kraken Pay, which supports instant, borderless transactions in over 300 cryptocurrencies and fiat currencies.

Surveys and Reports

United States: PYMNTS publishes Pay Later report

On 24 March 2025, PYMNTS published their ‘Pay Later Revolution: Redefining Consumer Spending’ report. This report explores the range of Pay Later providers, business models, and consumer use cases focusing on the evolution of credit cards, point-of-sale buy now, pay later (BNPL), and hybrid models that convert purchases into post-transaction instalments.

Some key takeaways include:

• Fixed monthly instalments appeal to consumers seeking predictable payments and better cash flow management.
• The popularity of modern BNPL models is forcing traditional banks to rethink how they integrate instalment options into their more traditional credit line-ups, and to do so as part of the shopping journey, rather than as a post purchase line-up.
• A new 'Pay in X days and instalments' model is emerging, with short-term, small-dollar BNPL providers expanding into longer-term credit, while larger BNPL providers are shifting to shorter-term, small-dollar loans.
• BNPL business models are increasingly resembling traditional credit cards, with consumer fees (interest, late fees, and subscriptions) driving most revenue for many providers.
• Traditional credit and BNPL providers are converging as payment flexibility becomes essential and Pay Later options are integrate into the checkout process.

Global: Broadridge Digital Transformation & Next-Gen Technology Study 

On 3 April 2025, Broadridge, a global Fintech leader, published their Digital Transformation & Next-Gen Technology Study. A key focus of the study is the evolving landscape of digital assets.

Key findings include:

• 71% of financial firms are making major investments in blockchain and distributed ledger technologies, up from 59% in 2024.
• 64% of firms are making big investments in cryptocurrency, up from 51% in 2024.
• 73% agree that there will be greater regulation and governance around digital assets moving forward.
• 40% believe that digital assets are increasingly relevant to their business.

Global: Paypers publishes Buy Now, Pay Later Report 2025

On 20 March 2025, The Paypers published their Buy Now, Pay Later Report 2025. The scope of the report spans Europe, the Americas, MEA, and APAC. The Paypers provides an in-depth analysis of global consumer behaviour, highlights emerging trends for 2025, explores recent regulatory developments, and includes insights from both solution providers and merchants.

Key findings include:

• A new payment method called ‘Save Now, Buy Later’ (SNBL) has redefined the concept of buy now, pay later (BNPL). SNBL incentivises consumers to save for big-ticket purchases while avoiding debt risks linked to BNPL.
• Budget-conscious travellers, and typically younger demographics, are actively seeking BNPL options to split the cost of their travel.
• The introduction of the second EU Consumer Credit Directive is expected to harmonise the requirements for BNPL businesses, taking a step forward in ensuring that transactions meet proper creditworthiness standards and disclosure requirements.
• Global BNPL transactions are predicted to grow by 13.7% annually, reaching USD 560 billion in 2025.
• The U.S. has emerged as the largest BNPL market in terms of value, China led in transaction volumes, while Sweden saw the highest BNPL penetration rates.

Authored by Charles Elliott, Virginia Montgomery, Sofie Gowran and Nurangis Sobirkhonova