Exactly one year ago, on the 14th November 2024, the UK Government set out a bold ambition through its National Payments Vision (NPV): to make account-to-account (A2A) payments — or Pay by Bank — a seamless and ubiquitous part of everyday life.

At TrueLayer, we welcomed that ambition. Pay by Bank was rightly identified as central to the UK’s growth mission, offering a faster, cheaper, and more secure way for people to pay directly from their bank account.

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Seamless account-to-account [Pay by Bank] payments are developed as a ubiquitous payment method […] enabling consumers to pay for goods and services in shops and online directly from their bank account.

National Payments Vision, 2024

Twelve months on, how close are we to that vision? Whilst progress is real, it remains uneven and incomplete. The coming twelve months will be decisive in turning policy ambition into widespread consumer and merchant adoption.

1. Delivering more certain payments for merchants

For merchants to put Pay by Bank front and centre at checkout, the user experience (UX) must be flawless. Merchant adoption drives consumer adoption, and for merchants, reliability and conversion are vital.

Today, that experience still varies by bank. The challenge now is to build a consistently excellent UX — one that just works every time, for every consumer. Achieving this requires a smart mix of commercial incentives, regulatory clarity, and focusing on the North Star set out in the NPV.

One of the most critical improvements on the horizon is Certainty of Fate (the ability for merchants to know instantly whether a payment has succeeded). Unlike card payments, which use authorisation codes, Pay by Bank payments, which are built on open banking technology, currently rely on settlement data. Certainty of Fate would give merchants the same confidence to release goods immediately, transforming ecommerce usability.

While Pay.UK and Open Banking Limited work towards this, there are high-impact improvements that could be delivered now:

• More granular failure codes, so merchants can help customers complete sales

• Consistent, high API availability to ensure reliability

• Simplified authentication flows to reduce friction

To stay on course for the NPV’s goal, regulators and industry should prioritise these short-term wins and make Certainty of Fate a non-negotiable early 2026 milestone, with transparent progress updates.

2. Designing new payment infrastructure to be cheaper, faster, and more certain

The UK’s Faster Payment System (FPS), nearly twenty years old, has served the nation well. But it was never designed for today’s digital payment volumes. The newly announced Strategy for Future Retail Payments Infrastructure is our chance to build the next generation of these rails.

The strategy sets out a number of outcomes that the new infrastructure will need to achieve:

The Government also specifically wants new infrastructure to ensure consumers can “pay for goods and services directly from their account to the merchant’s (account to account payments at point of sale), including by supporting open banking”, noting the role this new infrastructure will play in achieving the UK’s ambitions for Pay by Bank. It’s an opportunity to lower costs, improve speed, and unlock richer functionality.

Work will now be led by the Retail Payments Infrastructure Board (RPIB), where TrueLayer’s Chief Strategy Officer, Lisa Scott, represents the industry, to ensure delivery aligns with Government and regulatory goals.

Our ask is clear: the UK’s new payment infrastructure must be cheaper, faster, and more certain, supporting instant, data-rich payments that enable Pay by Bank to compete at scale.

3. Evolving regulation to put user experience at the core

The UK’s open banking ecosystem — now a £4bn industry — owes a lot of its success to regulation, namely the Payment Services Regulations (PSRs 2017) and the CMA’s Retail Market Order. Together, they created one of the world’s most innovative payment environments.

But while the PSRs have driven innovation, they have yet to unleash Pay by Bank as a true competitor to cards. HMT’s upcoming review of the regulations is a prime opportunity to change that:

• Removing friction in user journeys: streamlining authentication and requiring faster API response times.

• Raising the baseline for API quality: ensuring all banks meet consistent, high standards for UX and performance.

• Empowering oversight: giving regulators the tools to enforce reliability, availability and interoperability across the ecosystem.

By aligning regulation with user experience, the UK can use regulation as a tool to further build trust in, and adoption of, Pay by Bank.

4. Unlocking Pay by Bank’s ubiquity with recurring payments

If “seamless” describes how Pay by Bank works, “ubiquitous” describes where it works. We know adoption is accelerating, with open banking payments growing by 2.4 million month over month, with TrueLayer powering over half that growth.

But to make Pay by Bank truly ubiquitous, we must close functionality gaps and expand its use cases.

The next big leap for adoption is recurring payments. Today, you can use Pay by Bank for a one-off pizza, but not for your monthly music subscription.

Work is underway to change that. A new industry body will take forward delivery of recurring payments, with the FCA’s target set for the end of 2025. Once initial use cases are live, the next step must be enabling recurring payments for ecommerce, supporting one-click checkouts and “bank-on-file” experiences.

Despite a lot of work to get this body up and running, momentum is slipping, risking confidence and investment. To get delivery back on track, the industry needs a clear, agreed plan with milestones to bring recurring payments live to market. This plan should set out who is accountable for what and track progress transparently.

Industry must hit the new timeline for initial recurring payment use cases and commit to a similar timeline for an ecommerce rollout. Regulators and Government should hold industry players to account to keep delivery on track.

5. Cracking Pay by Bank at the point of sale

Online payments are only half the story. For many merchants, most transactions still happen in-store. True ubiquity also means Pay by Bank at the physical point of sale (PoS).

A recent regulatory development could unlock that. The CMA’s new “Strategic Market Status” (SMS) designation for both Apple and Google gives it new powers to ensure fair competition. That includes the ability to impose conduct requirements, potentially mandating that digital wallets and NFC technology support payment methods beyond cards. This could finally open the door for A2A payments at PoS.

The CMA should use these new powers to open up digital wallets and ensure fair competition. Doing so would complete the journey from online convenience to in-person ubiquity.

Make 2026 the year of delivery

The UK payments industry is grappling with a huge number of priorities, many of them are central to the NPV's ambition to make Pay by Bank seamless and ubiquitous. Whilst the first year of the NPV has built a strong foundation, the next twelve months must deliver tangible outcomes.

That means:

• A Certainty of Fate solution by early 2026

• A blueprint for a new payment infrastructure designed for instant, data-rich payments

• Regulation that embeds user experience at its core

• Recurring and in-person payments brought to market on time

The UK has led the world in fostering innovation before and it can do so again. By acting now, the Government, regulators, and industry can make Pay by Bank the next great British payments success story: faster, fairer, and truly frictionless for everyone.

Further reading:

• Future of payments: What the UK’s new payments stack means for Pay By Bank

• Realising the National Payments Vision: A step closer to a Pay by Bank scheme

• Government boosts Pay by Bank with National Payments Vision