
Remedies: Information, Transparency and Complexity (ITC) and Pricing Governance
Consultation closed: 5pm on 13 February 2026
Final directions issued: 30 July 2026
Implementation: Pricing Governance by 30 November 2026; full ITC requirements by 30 July 2027
The Payment Systems Regulator (PSR) has introduced two new directions that will meaningfully change how UK card scheme fees and card processing fees are explained, documented and governed across the payments ecosystem.
Following its market review, the PSR concluded that Mastercard and Visa face limited competitive pressure, fees have risen substantially and businesses accepting card payments have not been given enough clarity about what they are paying. Its two remedies - Information, Transparency and Complexity and Pricing Governance - were confirmed on 30 July 2026, with the main requirements taking effect over the following four to 12 months.
Here’s what Mastercard and Visa will need to do—and what the changes could mean for acquirers, merchants and fintechs operating in the UK payments market.
At a high level, the PSR wants to make card scheme pricing easier for acquirers—and ultimately merchants—to understand, forecast and reconcile.
The PSR imposed the ITC Direction using its specific-direction powers under section 54 of the Financial Services (Banking Reform) Act 2013.
Under the final direction, Mastercard and Visa will be required to:
• Provide clear baseline information about existing fees (ITC1). This must give acquirers enough information to understand what triggers each fee, how it is calculated, its likely impact and how it can be reconciled against transactions.
• Give advance notice of new or changed fees (ITC2). Relevant details will generally need to be provided at least six months before a new or amended fee takes effect. A narrower exception applies to new, optional opt-in services.
• Help acquirers reconcile fees. Following consultation, the PSR removed the proposed requirement for transaction-level identifiers. Instead, schemes must provide sufficient “fee logic” to help acquirers reconcile billed fees with the transactions that triggered them.
• Engage directly with acquirers. Mastercard and Visa must set out how they plan to comply, seek views from acquirers and then respond with a summary of the feedback and a confirmed implementation timetable.
• Implement the requirements within a defined timeframe. Mastercard and Visa must comply with the main ITC information requirements by 30 July 2027.
• Apply the final materiality threshold. The final direction uses a threshold of £250,000 in forecast annual gross revenue for certain requirements. This replaces the £100,000 annual net-revenue threshold originally proposed during consultation.
For acquirers, the aim is to make it easier to understand and check the fees they are being charged. For merchants, better information should feed through into more accurate billing, clearer pricing and better-informed decisions about optional services and avoidable fees.
Alongside transparency, the PSR is introducing stronger governance standards around how Mastercard and Visa make and document pricing decisions.
This direction was also issued using the PSR’s powers under section 54 of the Financial Services (Banking Reform) Act 2013.
In practice, the schemes will need to provide better evidence of how decisions are reached and demonstrate that they have considered the impact on acquirers, competition, innovation and payment-system resilience—not just their own commercial objectives.
The requirements include:
• Creating an Acquirer Fee Decision Record. Mastercard and Visa must maintain a written record for relevant decisions to introduce or change UK acquirer fees. This should capture the reasoning, supporting documents and internal approvals behind the decision.
• Applying a formal Pricing Decision Principle. The schemes must pay due regard to the interests of service users, including by assessing the reasonably foreseeable impact of a proposed fee on the acquiring side of the market, competition, innovation and resilience.
• Introducing compliance processes and training. Relevant policies, procedures, controls and employee training must be in place by 30 November 2026.
• Assigning senior accountability. An appropriately senior Executive Manager must oversee compliance and sign the required regulatory reports.
• Submitting annual reports. Mastercard and Visa will need to provide the PSR with an Annual Overview of relevant fee decisions and a Pricing Governance Compliance Report.
• Applying a financial threshold. The final requirements generally apply to fee decisions forecast to generate more than £250,000 in annual gross revenue. Anti-avoidance provisions apply where related fee decisions are separated or structured in a way that could circumvent the threshold.
The direction does not tell Mastercard or Visa what they can charge. Instead, it creates greater discipline, accountability and regulatory visibility around how their decisions are made.
Alongside the ITC and Pricing Governance remedies, the PSR is progressing a Regulatory Financial Reporting (RFR) remedy.
The PSR published a separate RFR consultation in May 2026, proposing that Mastercard and Visa provide information about the financial performance of their UK card operations. This would give the regulator a clearer and more consistent picture of the schemes’ UK revenues, costs and profitability.
Together, the measures are intended to help the PSR understand not only what fees are charged and how pricing decisions are made, but also the wider financial outcomes within the UK card payments market.
The consultation stage has now concluded, and the implementation clock is running:
1. Consultation responses closed on 13 February 2026. The PSR received responses from Mastercard, Visa, acquirers, trade associations and other stakeholders before finalising the two directions.
2. The PSR issued its final directions on 30 July 2026. The final rules included several changes to the original proposals, including a higher materiality threshold and a revised approach to fee reconciliation.
3. Implementation takes place in stages. Pricing Governance processes must be operational by 30 November 2026, while the main ITC information requirements must be fully implemented by 30 July 2027.
Mastercard and Visa will also need to engage with acquirers during the implementation period, with their first compliance communications due by 30 October 2026.
These changes signal a clear shift towards closer scrutiny of card scheme pricing in the UK.
For acquirers, clearer information should make scheme and processing fees easier to forecast, reconcile and explain to merchants. It may also require changes to internal billing, reporting and contract-management processes.
Merchants should benefit from greater visibility over their card acceptance costs, although much will depend on how effectively the additional information is passed down by acquirers.
Fintechs and other businesses operating across the payments value chain should assess how the directions could affect their contracts, pricing models, operational processes and compliance obligations.
As David Geale, Managing Director of the PSR, said when announcing the proposals:
“Greater transparency will equip acquirers and merchants with the information and confidence they need to navigate fees and make better decisions.”
The remedies will not cap scheme or processing fees. However, they should make those fees—and the decisions behind them—more visible and open to scrutiny.
At Founders Law, we regularly advise high-growth businesses on payments regulation, fintech compliance and commercial arrangements across the UK payments ecosystem. If you need help understanding how the new directions could affect your business, get in touch with our Fintech team.
When did the consultation close?
The PSR’s consultation on the detailed ITC and Pricing Governance directions closed at5pm on 13 February 2026. The regulator issued its final decision and directionson 30 July 2026.
Who do the new PSR card scheme fee rules affect?
The directions apply directly to Mastercard and Visa. However, they will alsoaffect acquirers, merchants, fintechs and other businesses that receive,process, reconcile or rely on information about UK card scheme and processing fees.
Whathappens now that the PSR has proceeded with the proposals?
Mastercard and Visa must implement the Pricing Governance requirements by 30 November 2026and the main ITC requirements by 30 July 2027. They must also engage with acquirers, introduce appropriate compliance processes and submit ongoing reports to the PSR.
The timing, statutory basis and final changes are supported by the PSR’s CP25/3consultation, original announcement and July 2026 final decision.