In July 2012, HM Treasury published the document: Setting the strategy for UK Payments as part of a consultation on the best models for the strategy development of the payment industry. The document outlined three options:
- improve the functioning of the existing Payments Council,
- introduce a new public body to set strategy across the UK payments industry: the Payments Strategy Board,
- introduce a utility type statutory regulator for the payments industry.
The EMA response to the consultation outlined that the representation of innovative payment service providers can be improved considerably. We outlined that the adoption of the first option could only work if it were to be accompanied by a radical change in representation that enabled participation on a basis that was transaction volume driven. This should enable a more meaningful participation in decision making and strategy for innovative payment service providers.
The representational issues that the e-money industry currently faces do not merit the third option of a utility type regulator. The second option could however assist in resolving the current shortcomings, but only with dual representation at both the public strategy board and the reconfigured Payments Council.
The next step is that the government will collect the responses and determine its future policy on that basis.