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Digital Economy Soundbite | Just landed: Response to the RPIB consultation on the Design of the Future Retail Payments Infrastructure

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    RPIB response: a thin, modular core for the next generation of UK retail payments (but the hard work sits around the core)

    The Retail Payments Infrastructure Board's response to its consultation on the future retail payments infrastructure, published on 4 November 2026, shows broad support from the 121 respondents. For firms, the message is that the core will be deliberately minimal and modular. Most of the commercial opportunity, and the responsibility, will likely sit with the market around the core: 

    • Modular and built for future payment types. The response reveals that the intention is to develop a single modular architecture built from reusable capabilities, as opposed to individual products. Messaging will use a common approach where practical. The thin core handles messaging, clearing, shared services and settlement coordination, which leaves potential for value-adding services to the private sector. 
    • Different forms of money must be interchangeable at par. The RPIB has kept its position that the core will connect to the Bank's RTGS service for settlement in central bank money. The core must also work with "regulated new forms of digital money as they may emerge". This puts into practice the "multi-money" vision Deputy Governor Sarah Breeden set out in September 2025 (see our earlier piece, UK digital payments – Welcome to the Multi-Moneyverse). As we noted in a separate update, the future of payments "is and will remain plural", and firms should design for optionality. 
    • Agentic payments. Respondents said payment activity should be identifiable, attributable to an accountable principal, and supported by verifiable authority. They wanted the core to distinguish between identity, authority and intent. Views differed on where safeguards should sit and how much autonomy agents should have. Firms building agents or delegated payment features will need to consider the impact of these distinguished features from a design perspective. 
    • Resilience and always-on operations. Given that RTGS operating hours may be extended (under separate consultation), this means that there more settlement cycles each day or settlement at weekends. Liquidity, treasury and operational models will need to cope with this and opens the possibility of product level operations.
    • Fraud, liability and point of sale. Richer data and stronger payee checks were supported by respondents, but liability, reimbursement and disputes were noted as needing arrangements outside the core.

    What's next?

    The next phase is a co-creation phase with industry starting in November. The Blueprint is due in Spring 2027 and will then pass to the industry-led Delivery Company for detailed design, procurement and build. Respondents strongly preferred a phased migration to a "Big Bang", and expressed concern against switching off Bacs and Direct Debit before the replacements are proven. 

    Authors: Fiona Ghosh, Partner; Max Savoie, Partner; Caitlin Goodman, Junior Associate.

    The information provided is not intended to be a comprehensive review of all developments in the law and practice, or to cover all aspects of those referred to.
    Readers should take legal advice before applying it to specific issues or transactions.