Pay by Bank protections: a modern approach

Robert kerrigan
Robert Kerrigan, Chief Operating Officer
12 Jun 2025
Pay by bank phone

Pay by Bank is the fastest-growing payment method in the UK. It is already delivering benefits to millions of consumers and retailers.

Its success is aligned with Government and regulatory ambitions to create more payment choice, and reduce the cost of payments. It’s rapidly proving to be the most effective way of disrupting the card-scheme duopoly, whose dominance has resulted in UK businesses being overcharged and buried in complex, opaque pricing.

Pay by Bank eliminates the risk of card fraud, enables instant refunds, and gives retailers immediate access to funds — cutting out unnecessary intermediaries and dramatically reducing costs. That’s why millions of people use it every day, and why major retail brands are embracing it.

As we grow and enter new sectors, we’re constantly thinking about how to best meet the needs of consumers and businesses.

We designed Pay by Bank to be a safe, secure and efficient way to pay. Now we are focused on making sure it is the most convenient way to pay for goods and services of all types. We’re doing this by reducing the cost of payments with consumer incentives (coming soon); and we’re designing new protections for when consumers have purchase issues.

On protections, in recent months we have:

  • Undertaken a YouGov survey of 4,000 consumers on their use of and experience of refunds and chargebacks

  • Developed a blueprint for a new, efficient way to manage purchase issues, and merchant insolvency which we will test with merchants

  • Worked with banks and other fintechs on the options for additional protections in Pay by Bank

What are we solving?

In terms of consumer protection in Pay by Bank, there are three things to focus on:

  1. Security: What happens if a payment is incorrect or unauthorised?

  2. Insolvency: What happens if a business fails when you’ve paid in advance?

  3. Disputes: What happens if a consumer and merchant disagree about a purchase?

Solutions

1. Security

The financial regulation that underpins Pay by Bank prioritises safety and security of payments. Pay by Bank does not involve sharing any card or security details online — so unauthorised transactions (where card details are stolen to make purchases), are a thing of the past — removing one of the primary reasons consumers use chargebacks. With Pay by Bank, if something goes wrong with your payment (such as the wrong amount is taken, or there's a duplicate payment), you have the exact same legal protections you have with any other payment option: you can get a refund from your bank.

2. Insolvency is being solved

TrueLayer primarily works with large enterprise merchants, so insolvency is a very low risk. However, as outlined in our 2025 Pay by Bank update, we are looking at ways to protect against merchant insolvency, to give consumers more trust and security against these rare events. We are exploring ways to add targeted protection for consumers, for edge-cases such as event cancellations. There are multiple ways to solve these issues, including looking at how liability is allocated and what combination of strategies such as merchant vetting, holding funds, or insurance can be used with Pay by Bank. The solutions we’re focusing on now are those that can add protection, without adding friction or cost to merchants or consumers.

3. Disputes need smart, modern processes — not outdated chargebacks

Businesses and consumers both struggle with card chargebacks: the complexity, the high costs, the slow processes and the refund fraud they enable (research shows that 48% of adults believe it is ‘reasonable’ to commit refund fraud). As a result, refund fraud is estimated to account for 60-80% of all chargebacks, adding £128m in costs for UK merchants, which are then passed back to honest consumers. The chargeback system, therefore, is not fit for purpose and has no right to be part of the conversation when we talk about purchase protection for Pay by Bank. We can, and will, do better.

Our blueprint explores how technology can help consumers who aren’t able to resolve an issue directly with a seller, and the role a central dispute resolution process can play, enabled by modern technology. We will do this without recreating the complexity or cost of the card scheme chargeback system.

An approach like this will offer consumers greater confidence and trust, without undermining the simplicity and efficiency that merchants and consumers love about Pay by Bank.

Next Steps

This work will inform the new central scheme for Pay by Bank: The UK Payments Initiative has now been established with the backing of the Financial Conduct Authority and will formally launch later this year. This is a cohort of 32 banks and fintechs who will agree on a set of rules and operating principles for Pay by Bank, Bank on file, and other open banking features. Together, we will drive Pay by Bank forward to make it a ubiquitous payment method as outlined in the government's national payment vision.

In the meantime, we will be publishing the results of our research and details of our blueprint and testing, to inform thinking and further progress.

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Hey, I'm Andy from TrueLayer, and I'm going to try and tell you everything you need to know about Pay by Bank—in just ninety seconds.  Let’s start the clock.  Let’s keep it simple. What is Pay by Bank? It’s a payment method that lets you pay directly from your bank account via your banking app—with zero need for card networks.  That could mean buying pizza, paying for flights, or just about anything in between. And it’s actually pretty easy—and very quick.  It looks a bit like this: start by tapping the Pay by Bank button, then choose your bank from the list.  If you’ve used it before, we can even preselect your preferred bank. You then review the payment, and you’re seamlessly redirected to your bank app to approve it using secure biometrics.  That’s Face ID or a fingerprint, to you and me. And that’s it—success. But no time to relax—we're on the clock!  Now, this might be the first time you’re hearing about it, but every month in the UK, 27 million payments are made using Pay by Bank. And most people who haven’t tried it yet say they’d be happy to—if given the option. On the merchant side, nine out of ten businesses are already planning to adopt it in one way or another.  So what’s in it for businesses?  Number one: more potential sales. No cards means no long card numbers, no clunky 3DS2—just a smoother experience from start to finish. And it converts.  Number two: because payment details are pre-populated and verified with biometrics, things like card-not-present fraud, chargebacks, and authorized push payment fraud are virtually eliminated.  Number three: lower costs. Without all the intermediaries and manual admin, the total cost of Pay by Bank is typically lower than card payments.  I'm running out of time—one last benefit: instant refunds. And trust me, shoppers love instant refunds.  And breathe. That was a lot to cram into ninety seconds.  If you’d like to take your time and learn more about Pay by Bank—and why brands like Just Eat Takeaway, lastminute.com, Ryanair, and Papa John’s already offer it at checkout—you can read our in-depth guide. There should be a link on screen now.  And that’s it. Thanks for watching.
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