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Sterling settlement runs through the Bank of England's RTGS service (renewed as RT2, live 28 April 2025) and CHAPS. The UK was the first G7 central bank (2017) to extend direct RTGS settlement-account access to non-bank PSPs, enabling direct access to FPS, Bacs, CHAPS and LINK; the first non-bank PSPs opened accounts in 2018. Since 2021 the BoE has offered omnibus accounts to recognised payment-system operators to pool participant funds and settle in central-bank money (enabling the world's first blockchain-based wholesale settlement). A consolidated RTGS access policy was published April 2025. The BoE is reviewing CHAPS direct-access thresholds and concentration risk (2024 discussion paper).
The settlement infrastructure is also evolving at the wholesale layer. In RTGS, an omnibus account lets recognised payment-system operators pool participant funds and fully fund wholesale settlement in central-bank money; a consolidated access policy covering settlement accounts, services and omnibus accounts was published in April 2025. Since 2021, omnibus accounts have enabled the world's first blockchain-based wholesale settlement in central-bank money, and the BoE is reviewing CHAPS direct-access thresholds and concentration risk via a 2024 discussion paper. Omnibus accounts thus enable tokenised and blockchain wholesale settlement in central-bank money — a legal-infrastructure and settlement-finality vector that is otherwise under-indexed.
Outlook
W12 is an established standing position. The structural picture — direct non-bank PSP RTGS access since 2018, RT2 live since 28 April 2025, and omnibus accounts enabling blockchain wholesale settlement — is settled, with the live forward item being the BoE's review of CHAPS direct-access thresholds and concentration risk. The module's spine remains the narrowed bank versus non-bank settlement-access asymmetry, which underpins the structural advantage of UK non-bank PSPs relative to peer jurisdictions.
Correspondent Banking, Settlement & Access
The structural spine of this module remains the asymmetry between bank and non-bank access to settlement and correspondent-banking arrangements, and this cycle's developments bear on the enforcement architecture that governs that access rather than on the underlying asymmetry itself. The Administrative Court's ruling in [2026] EWHC 64 (Admin) on the PSR's section 54 FSBRA 2013 power to cap cross-border interchange fees, together with the CAT Trial 2 pass-on findings in [2026] CAT 11, bear directly on the future enforcement architecture for scheme access and settlement questions once the PSR's functions are absorbed into the FCA under the Financial Services and Markets Bill 2026-27.
This matters for settlement-access questions specifically because the interchange-fee cap power under section 54 is one of the principal levers currently used to police fair access to card-scheme settlement arrangements; how that power is interpreted and, in due course, administered by the FCA rather than the PSR, will shape the practical settlement-access environment for both bank and non-bank payment institutions going forward. The FSBRA 2013 designation regime underlying this power is being retained through the institutional transition, meaning the legal basis for settlement-access enforcement continues even as the administering body changes.
Outlook
Watch for how the FCA's absorption of PSR enforcement functions affects the practical administration of the section 54 interchange-fee cap power, and for any further judicial development in the EWHC or CAT proceedings bearing on settlement and scheme-access questions before the institutional transfer is complete.
2 earlier distinct update(s)
Correspondent Banking, Settlement & Access
The UK's correspondent-banking and payments-insolvency plumbing hardened further this cycle. Binding from 7 May 2026, mandatory CASS10A resolution packs and standardised safeguarding-account acknowledgment letters are intended to enable fund tracing for non-bank payment and e-money firms after insolvency, though this remains sourced to a single tier-3 legal-commentary source pending further corroboration. A fuller CASS-style statutory-trust Post-Repeal Regime remains deferred to a future HM Treasury payment-services-law consultation, expected later in 2026 or in 2027, and would require amending the Payment Services Regulations 2017 and the Electronic Money Regulations 2011. This module's analytical spine remains the structural asymmetry between banks' direct access to settlement infrastructure and non-bank payment and e-money institutions' continued reliance on indirect access and safeguarding arrangements rather than deposit protection.
Separately, in Gibraltar, the GFSC, the Gibraltar government and crypto exchange Bullish are reported to be developing an independent crypto-derivatives clearing-house oversight framework under Gibraltar's DLT regime. No primary GFSC instrument text has been retrieved this cycle; the development rests on a single tier-4 trade-press source and should be treated as provisional. If formalised, such a framework would fill a structural gap relative to the exchange-self-clearing model common elsewhere, potentially positioning Gibraltar competitively in the virtual-asset derivatives space.
Outlook
HM Treasury's Post-Repeal Regime consultation remains a multi-year horizon item with no fixed date, expected later in 2026 or in 2027. Gibraltar's crypto-derivatives clearing-house framework is expected to develop further in the fourth quarter of 2026, though confirmation depends on GFSC publishing primary instrument text that has not yet surfaced this cycle.
Correspondent Banking & Settlement Access
The analytical spine of this module is the access asymmetry between bank PSPs and non-bank payment institutions and e-money institutions. In the UK, non-bank PSPs have a statutory right of access to payment systems under the Payment Services Regulations, and the Bank of England has published guidance on access to UK payment systems for non-bank PSPs. No new structured findings were developed on this topic in the current cycle; the source register contains a Bank of England page on non-bank PSP access that was retrieved but not developed into structured claims.
The gaps register records that settlement access for non-bank PSPs remains under-indexed this cycle, with the source set dominated by FCA and Bank of England primary regulatory material on the crypto and stablecoin theme.
Outlook
No date-certain forward items are currently recorded for this module. A dedicated UK pass on non-bank PSP settlement access is flagged for the next research cycle.
Sources and findings (3)
- T1Bank of England — Functionality of the new RTGS service — Non-bank PSPs are eligible to access RTGS settlement accounts subject to resilience standards; the first non-bank PSPs opened settlement accounts in RTGS in 2018, and the renewed RTGS service (RT2) went live on 28 April 2025.
- T1Bank of England — Access policy for RTGS settlement accounts and services — In RTGS an omnibus account lets recognised payment-system operators pool participant funds and fully fund wholesale settlement in central-bank money; a consolidated access policy covering settlement accounts, services and omnibus accounts was published April 2025.
- T1Bank of England — Reviewing access to RTGS accounts for settlement — The BoE was the first G7 central bank (2017) to offer RTGS access to non-bank PSPs, and since 2021 has offered omnibus accounts enabling the world's first blockchain-based wholesale payment system settling in central-bank money; it is reviewing CHAPS direct-access thresholds and concentration risk.