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Commercial variable recurring payments under the UK Payments Initiative scheme went live 2 June 2026 (later than the Q1 2026 PSR estimate), covering utility, financial-services, government and charity payments in Wave 1.
The commercial-scheme step is concrete. The FCA and PSR confirmed on 16 December 2025 that the UK Payments Initiative (UKPI), a new company formed by 31 firms, will operate a commercial VRP scheme, with first live payments expected Q1 2026, expanding to utilities, financial-services and government payments. The Data (Use and Access) Act 2025 provides a statutory foundation, and HMT is expected to legislate in 2026 to give the FCA open-banking rule-making powers. The first commercial-VRP scheme is a structural step toward A2A displacing cards in recurring payments.
Outlook
W9 is escalating. The near-term event is the first live commercial-VRP payments under UKPI, expected Q1 2026, with expansion into utilities, financial-services and government payments to follow. On the legislative horizon, HMT is expected to legislate in 2026 to grant the FCA open-banking rule-making powers under the smart-data framework, paving the way toward open finance. Together with 16m+ users and 53% YoY payments growth, these position A2A as a structural competitor to cards in recurring payments.
Product Innovation & Market Development
Commercial variable recurring payments (cVRP) under the UK Payments Initiative scheme reached live status with Wave 1 going live on 2 June 2026. This wave covers utility, financial-services, government and charity payment use cases, representing the first tranche of a broader planned rollout of account-to-account variable recurring payment capability beyond the sweeping use case that preceded it. The 2 June 2026 live date supersedes the Payment Systems Regulator's earlier estimate, published in its December 2025 delivery update, that first live payments under the scheme would occur in the first quarter of 2026; the scheme reached live status roughly five months later than that original estimate indicated.
The delay between the PSR's original Q1 2026 estimate and the actual 2 June 2026 live date is itself a data point on delivery timelines for new account-to-account payment infrastructure in the UK, suggesting that scheme-level delivery estimates for VRP expansion should be treated with some caution until a wave actually goes live. With Wave 1 now live, the practical question for market participants shifts from delivery timing to adoption: transaction volumes and merchant uptake across the covered use cases (utility, financial-services, government, charity) are now the operative measures of the scheme's traction.
Outlook
Adoption and transaction-volume growth across the utility, financial-services, government and charity use cases covered by cVRP Wave 1 are the items to watch next. Whether further waves extending coverage to additional payment use cases have been scheduled was not evidenced this cycle.
1 earlier distinct update(s)
Product Innovation & Access Regulation
No new structured findings were developed for this module in the current cycle. The gaps register notes that the source register contains open-banking pricing signals — including a joint FCA-PSR statement on open-banking pricing models — that were not developed into structured findings this cycle and are flagged for the next research pass.
The distinction between W9 (regulatory product-access themes such as open banking, BaaS, and BNPL regulation) and W13 (specific product launches and commercial events) is maintained: the open-banking pricing signal is a W9 item; any specific product launches would be W13.
Outlook
No date-certain forward items are currently recorded for this module. The open-banking pricing signal is flagged for development in the next research cycle.
Sources and findings (4)
- T1FCA — Open banking: a year of progress — FCA figures show open banking surpassed 16m users in 2025 with total payments up 53% year on year; VRPs now account for c.16% of open-banking transactions, with average API availability of 99.22% (unweighted) in October 2025.
- T1FCA/PSR — Commercial variable recurring payments update — The FCA and PSR confirmed (16 Dec 2025) that the UK Payments Initiative (UKPI), a new company formed by 31 firms, will operate a commercial VRP scheme, with first live payments expected in Q1 2026, expanding to utilities, financial-services and government payments.
- T3The Payments Association — state of open banking 2026 — The Data (Use and Access) Act 2025 provides a long-term statutory foundation for open banking within the UK's 'smart data' framework, and HM Treasury is expected to legislate in 2026 to give the FCA new powers to set open-banking rules, paving the way to open finance.
- T3Mordor Intelligence (citing BoE digital pound update) — The Bank of England continues digital-pound design work, with a January 2025 progress update highlighting plans to support interoperable retail payments in a tokenised economy.