PSD3 & UK Payments: 3 Things Firms Need to Act on Now

The payments rulebook is changing again! 

The EU’s forthcoming Payment Services Directive 3 (PSD3) and its accompanying Payment Services Regulation (PSR) signal the next big chapter in the EU’s payment services framework.  

And while the UK is no longer bound by EU law, these reforms still matter. UK regulators are watching closely, and firms with cross-border customers, or those that want to stay ahead of best practice, should be watching too.

Here’s where to focus now if you want to stay compliant, competitive, and credible. 

1. Clarity Counts: Make Customer Communications Crystal Clear

PSD3 pushes for transparency meaning firms will

need to present fees, exchange rates, and key terms in plain language, both before and after each transaction. 

For UK firms, this means auditing every touchpoint of the customer journey — from app interfaces to email confirmations, and asking, “Would a customer instantly understand what they’re paying for and when?” 

Design-out ambiguity in practice: A common pain point is vague language like “foreign transaction fees may apply” or “charges vary depending on your provider.”  Replacing these with exact figures or clear scenarios (“£2.50 flat fee per transaction” or “2% of the transfer amount”) eliminates confusion. Similarly, presenting fees before conversion and not buried post-transaction helps “design out” misunderstanding entirely. 

For UK payment firms, this means pressure testing every step of the customer journey: are your disclosures easy to find, easy to read, and easy to understand?  

Let’s not forget that this is already a requirement under the Consumer Duty. PSD3 just raises the bar. Aligning early gives firms a dual compliance edge: 

• Outcome 2 (Consumer Understanding): PSD3-style clarity directly supports the Duty’s emphasis on plain, timely and actionable information. 

• Outcome 3 (Consumer Support): Transparent disclosures reduce friction and complaints, improving customer confidence and satisfaction. 

Action: Map out precisely where you show key information and audit it for clarity. Remove jargon and ambiguity. If customers can’t easily compare your pricing or timelines, regulators will soon notice.

2. Standardise Fees: No More Hidden Costs 

A significant aim of PSD3 is standardisation, forcing providers to present charges in a consistent, comparable way. The goal is to eliminate confusion and let customers make informed choices. 

Even if you are UK-based, this matters, especially those servicing EU customers directly or indirectly through affiliates and passporting arrangements.

The Payment Systems Regulator (PSR) is also tightening its expectations on interchange and scheme fee transparency building on its ongoing market reviews that emphasise clear disclosure and competition through comparability, which dovetails neatly with PSD3’s template-based fee formats. 

Action: Benchmark your current pricing disclosures against the expected PSD3 templates. Test them with users; can they understand and compare your fees without a spreadsheet?  

3. Fortify Fraud Defences: Broader Responsibilities, Higher Stakes

PSD3 expands liability for authorised push payment (APP) fraud, pulling more players, such as wallet providers and TSPs, into the accountability net. 

This complements, although diverges slightly from the UK’s APP reimbursement regime by setting clearer, Pan-European obligations for fraud prevention, not just redress.  

The directive also tightens Strong Customer Authentication (SCA) rules and gives firms more scope to use personal data for fraud prevention without explicit consent under GDPR. The message is clear – prevention beats reimbursement.  

Action: Review your existing fraud response plan and test your detection systems. Consider real-time behavioural analytics and ensure your approach aligns with UK APP reimbursement rules. 

Who Will Feel It Most? 

While large banks are well-equipped for regulatory adaptation, smaller fintechs, e-wallets, and non-bank PSPs may feel the pressure first. These firms often rely on partners or white-labelled infrastructure,  areas that PSD3’s accountability changes will bring into sharper regulatory focus. 

The Bigger Picture: Trust as a Competitive Edge 

While the UK may not copy PSD3 word for word, the themes are aligned; transparency, fairness, and resilience.  

Firms that act early by cleaning up disclosures, standardising pricing, and tightening fraud controls, will not only be compliant, they’ll be trusted. And in payments, trust is everything.  

Need a Head Start?  

Are you ready to navigate the complexities of evolving payment regulations?

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Adempi helps firms navigate regulatory change with targeted healthchecks, expert guidance and practical solutions to ensure your business remains compliant and competitive.  

If you’d like to speak to one of the team about The Payments Rulebook or anything else, you can reach us at contact@adempi.co.uk or on 0203 925 4761 to prepare your business for whats next

Adempi - FCA Compliance Consultants.