The Payments Newsletter including Digital Assets & Blockchain, December 2025

On 20 November 2025, we gathered banks, payments firms, FinTechs, legislators, regulators and policymakers at our London office for the annual Hogan Lovells Payments Conference 2025. At the event we explored key themes such as AI driven innovation across the payments value chain, the rise of digital currencies such as stablecoins and CBDCs and the future of payments regulation – highlighting how evolving frameworks must balance consumer protection with enabling innovation – as well as cybersecurity risks and fragmentation challenges. Further discussions focused on fighting financial crime, BNPL and alternative payments methods.

For a summary of the key takeaways from each session at the conference, take a look at this Our Thinking article. 

China and Vietnam: Launch of cross-border QR code payment system

On 2 December 2025, China and Vietnam officially announced a bilateral QR code payment service in Hanoi, marking a significant step in regional payment connectivity. The initiative enables Chinese consumers to make payments at Vietnamese merchants using the national VietQR system, leveraging China’s mobile payment tools.

The service was introduced by the National Payment Corporation of Vietnam, UnionPay International, the Industrial and Commercial Bank of China and Vietcombank, following a Memorandum of Understanding signed in October 2024 and a subsequent four-party agreement to establish technical connectivity and settlement frameworks.

Key features include:

• Chinese visitors can now scan VietQR at participating merchants, including major retailers, tourist sites and hospitality venues.
• The system aims to increase the use of local currencies in cross-border transactions and support trade, tourism and broader economic cooperation between the two countries.

The launch follows close collaboration under the guidance of the State Bank of Vietnam and marks a significant milestone in strengthening cross-border payment infrastructure.

New Zealand: Open Banking goes live under phased rollout

On 1 December 2025, the New Zealand government announced that Open Banking had officially gone live in New Zealand, marking the first stage of a phased implementation under the Customer and Product Data Act 2025.

The four major New Zealand banks ANZ, ASB, BNZ, and Westpac are now required to have Open Banking systems operational, with Kiwibank scheduled to follow in June 2026 for payment services and December 2026 for other Open Banking functions.

The framework aims to foster innovation and competition by allowing customers to share financial data securely with accredited third parties. Key safeguards include explicit customer consent and accreditation requirements overseen by the Ministry of Business, Innovation and Employment (MBIE), which has introduced a trust mark for approved data requestors.

Australia: Treasury consults on mandatory anti-scam regime for banks, telcos and digital platforms

On 28 November 2025, the Australian Treasury opened a public consultation on a draft Competition and Consumer (Scams Prevention Framework – Regulated Sectors) Designation 2025, which would prescribe banks, telecommunications providers and certain digital platforms (including social media, instant messaging and search services) as the first sectors to be regulated under the new Scams Prevention Framework (SPF) by 1 July 2026.

The SPF, legislated earlier this year, introduces mandatory industry codes of conduct setting out specific obligations for each sector to strengthen scam prevention. Designating the banking sector will make authorised deposit-taking institutions subject to SPF obligations, including proactive anti-scam measures and compliance with SPF principles and any future code. Similar requirements will apply to telcos and major digital platforms.

The Treasury is also seeking feedback on external dispute resolution arrangements, which would involve the Australian Financial Complaints Authority as the single body for unresolved complaints. ASIC, ACMA and ACCC are expected to act as sector regulators for banking, telecommunications and digital platforms respectively.

Submissions on the current consultation remain open until 5 January 2026. The Treasury has also confirmed that future opportunities to comment on sector codes and rules will occur throughout 2026.

New Zealand: New banking scam protections and compensation go live

On 28 November 2025, the New Zealand Banking Association (NZBA) announced that an update to the Code of Banking Practice introducing new scam protections and a compensation framework for customers had come into effect. The changes target authorised payment scams where individuals are tricked into sending money to criminals and strengthen banks' obligations to prevent and respond to fraud.

The updated Code introduces five key commitments, including: (1) pre-transaction warnings for certain payments, (2) a Confirmation of Payee service, (3) enhanced monitoring and the ability to delay or block high-risk transactions, (4) 24/7 scam reporting channels and (5)  sharing scammer account details between banks to freeze funds where possible. Where a bank fails to meet these commitments, it will compensate all or part of the loss for eligible customers. Banks will also continue to reimburse losses for unauthorised account access.

The NZBA described the changes as a prevention-led approach to tackling scams, emphasising shared responsibility across banks, tech platforms and consumers. The updated Code of Banking Practice is now in force and available on the NZBA website.

India: Central bank issues final guidelines for digital banking channels

On 28 November 2025, the Reserve Bank of India (RBI) published its final guidelines for digital banking channels, setting out new requirements for customer consent, risk controls, and operational standards.

The guidelines require banks to obtain and record explicit customer consent before providing digital banking services and clarify that opting for digital channels cannot be made mandatory for access to core facilities such as debit cards. Banks must implement robust risk mitigation measures, including transaction limits, velocity checks and fraud monitoring and deploy transaction surveillance systems based on risk assessment.

Additional provisions include restrictions on displaying third-party products unless specifically permitted, clear communication of SMS and email alerts for all account operations and ensuring mobile banking services function independently of network providers. RBI also confirmed that stricter requirements from payment system operators will prevail where applicable.

European Union: Parliament and Council reach provisional agreement on PSD3 and PSR

On 27 November 2025, the European Parliament and the Council of the EU issued press releases announcing that they have reached a provisional political agreement on the texts of the proposed Directive on payment services and electronic money services (PSD3) and Regulation on payment services in the EU (PSR). Subject to completion of work on the technical elements of the payments package, payment service providers (PSPs) should expect to see the final texts in the coming weeks.

Take a look at this Our Thinking article for more on this development.

European Union: EBA publishes peer review report on authorisation under PSD2

On 5 December 2025, the EBA published a follow-up report to its 2023 report on its peer review on authorisation of payment institutions and e-money institutions under PSD2.

The report covers authorisations between 2022 and 2024, and assesses how supervisors have implemented the 2023 recommendations. It focuses on matters including authorisation processes, implementation of the EBA guidelines on authorisation, and governance and internal controls.

Among the key findings were the following points:

• While most supervisors have improved efficiency by providing clearer guidance, engaging with applicants earlier on and streamlining internal procedures, delays remain as not all changes have had a significant impact; and
• Supervisors report better assessments of applicants' governance and internal control mechanisms, but divergent implementations persist in these areas. This risks creating an uneven playing field and regulatory arbitrage. The report highlights in particular that further efforts are needed to close remaining gaps in anti-money laundering and countering the financing of terrorism controls.

Supervisors are encouraged to address the remaining gaps, and work towards greater convergence in governance and internal control frameworks across the EU.

United Kingdom: HM Treasury publishes update on creating provisional authorisation regime

On 5 December 2025, HM Treasury (HMT) published a policy paper providing an update on creating a provisional licences authorisation regime (part of the government’s March 2025 regulation action plan).

The aim is to reduce the barriers firms face when seeking authorisation by enabling the FCA to grant them time-limited permissions so that they can get "up and running" in a controlled environment with strong regulatory oversight, while working towards full authorisation.

The regime is expected to be most appropriate for early-stage firms, particularly those with an innovative business model, that would otherwise struggle to meet the usual requirements to obtain authorisation in a reasonable timeframe.

Key points from the policy paper include the following:

• The regime is intended for firms that are not already authorised and are seeking permission under Part 4A of the Financial Services and Markets Act 2000 (FSMA) for activities already within the FCA's perimeter.
• The FCA's assessment of applications for provisional licences against the threshold conditions will be proportionate, i.e. its judgements will be tailored to both the firm's stage of development and the fact that the firm has applied for a time-limited authorisation.
• Provisional licences will apply for a fixed duration of up to 18 months. This may be extended in limited circumstances.
• Firms will be required to comply with relevant rules and continue to meet the threshold conditions during the provisional licence period.
• Firms will exit the provisional licence regime on achieving full authorisation.

Introducing a provisional licence regime will require primary legislation, which the government will bring forward when Parliamentary time allows. The FCA will engage with the industry on the design of the regime and consult as necessary.

United Kingdom: Latest edition of Regulatory Initiatives Grid published and FCA/PRA updates to government on work to support growth

On 11 December 2025 the Financial Services Regulatory Initiatives Forum, which includes the FCA, the Bank of England (BoE), the PRA, the Payment Systems Regulator (PSR), The Pensions Regulator and HM Treasury, published the latest edition of the Regulatory Initiatives Grid.

The Grid sets out the planned regulatory initiatives for the next 24 months and is published twice a year.

Grid items of relevance to payments and digital assets include:

• Overnight safeguarding facilities in the BoE’s RTGS service for non-bank payment service providers (NBPSPs): The BoE is considering offering overnight safeguarding facilities to FCA-authorised NBPSPs, including e-money and payment institutions, that hold a Real-Time Gross Settlement (RTGS) settlement account. The Grid entry explains that allowing NBPSPs to safeguard client funds in RTGS could help to enhance growth opportunities and innovation by levelling the playing field in the payments ecosystem between commercial banks and NBPSPs. It could also provide benefits to operational risk and financial stability. Any benefits will be evaluated relative to the potential risks from increased NBPSP access to the BoE’s balance sheet as well as the implications for monetary and financial stability. Industry engagement is ongoing and expected to complete by the end of 2025. The BoE then expects to communicate the outcome of its policy decision, including any next steps for implementation, in H1 2026 (marked for Q1 2026 in the indicative timeline in the Grid).
• Contactless payment limits: Final standards following the FCA’s September 2025 consultation are expected in Q4 2025.
• Changes to safeguarding requirements for payments and e-money institutions: In addition to the main timing of May 2026 for the coming into effect of the FCA’s new rules under its Supplementary Regime (which remains unchanged), the Grid also mentions that the Financial Reporting Council (FRC) is developing a safeguarding assurance standard. The FRC started monthly working group meetings in September 2025 which will run until April 2026, with a view to developing proposals for consultation in H2 2026 (marked for Q2 2026 in the indicative timeline in the Grid), and publication of the final assurance standard in H1 2027.
• PSR market review of card scheme and processing fees: A provisional decision on remedies is expected from the PSR in December 2025, with the consultation period planned for December 2025 to February 2026. A final decision on remedies will be due in May to June 2026.
• PSR market review of cross-border interchange fees: A PSR final decision on remedies following the market review is planned for January to June 2027 (ie H1 2027).
• Authorised Push Payment (APP) scam prevention: Publication of the independent 12-month evaluation of the PSR’s APP fraud policies is due in Q3 2026.
• National Payments Vision (NPV) implementation: The Payments Forward Plan is now due in Q1 2026 rather than Q4 2025. Retail Payments Infrastructure Board set up and design consultation is planned for Q1 2026. Delivery Company set up is due in H1 2026.
• Modernising payments assimilated law: Milestones are to be set out in the NPV’s Payments Forward Plan (Q1 2026).
• Managing the failure of systemic digital settlement asset firms: This is now in the Grid’s Annex of completed or discontinued initiatives. The commentary states that HMT continues to develop this initiative and is considering next steps.

In addition, on 10 December the FCA and the PRA published letters to the government (dated 9 December 2025) providing updates on their work during 2025 to support the government’s pro-economic growth agenda.

The FCA’s letter contains an Annex listing the actions taken this year to progress the growth commitments that it made in a letter to the government in January this year. Points of interest from the letter and a related press release include:

• The FCA’s 2026 supervisory approach will reflect a ‘bolder risk appetite’ in support of growth, although it suggests that a ‘clearer articulation of the Government’s risk appetite with metrics would help anchor this shift and support innovation and growth’.
• Stablecoin payments are a particular priority for 2026. There is reference in the press release to the fact that the FCA is inviting firms that plan to issue a stablecoin in the UK and wish to test their products in its regulatory sandbox to apply by 18 January 2026 (see the separate item on this development under ‘Regulatory Developments: Digital Assets’). The FCA also points out that it is working closely with the Bank of England to develop the regulatory regime for stablecoins.

The PRA’s letter provides a brief update on the five pro-growth changes that it intended to make to its regulatory regime and the three proposals for it to explore jointly with HMT and the Department for Business and Trade in 2025.

Nigeria: Central bank introduces stricter cash withdrawal limits

On 3 December 2025, the Central Bank of Nigeria (CBN) issued a circular introducing sweeping changes to its cash management policies to curb cash dependency and tackle security and money-laundering risks.

With effect from 1 January 2026, individuals will be limited to cumulative weekly withdrawals of ₦500,000, while corporates will be capped at ₦5 million (around US$346 and US$3,438, respectively). The circular also confirms the removal of fees on excess deposits as part of broader efforts to reduce reliance on cash and strengthen compliance across the financial system.

The revised policies apply to banks and other financial institutions and form part of the CBN's strategy to mitigate risks associated with large cash transactions. 

United Kingdom: Banks and EMIs face detailed new information and account direct deduction obligations as Public Authorities (Fraud, Error and Recovery) Act 2025 receives Royal Assent

The Public Authorities (Fraud, Error and Recovery) Act 2025 received Royal Assent on 2 December 2025.

The Act includes powers for the Minister for the Cabinet Office and the Department of Work and Pensions (DWP) to issue ‘account information notices', ‘general information notices', ‘further information notices' and ‘direct deduction orders' to banks and e-money institutions (EMIs) in relation to recovery of fraudulent or erroneous payments from accounts, as well as a DWP power to issue ‘eligibility verification notices' to banks and EMIs regarding the checking of eligibility criteria for certain State benefits. There will be fines (including daily default fines) for no, incorrect or late compliance with the new requirements.

Banks and EMIs face material implementation costs and risks of reputational harm once the relevant provisions of the Act enter into force in accordance with secondary legislation yet to be introduced.

For more on the Act, see this Our Thinking article.

United Kingdom: Government publishes research on data standards for smart data schemes

On 28 November 2025, the Department for Business and Trade (DBT) published a report examining how existing data standards can support future smart data schemes and setting out nine design principles for new standards.

The report highlights that while data standards are essential, success will also depend on factors such as customer consent, accreditation and data security. It stresses the need for interoperability to avoid fragmentation and maximise benefits. The DBT's research found that data standards already exist in priority sectors including finance, energy, property and retail, but significant work is required before these can fully support smart data schemes.

The report also proposes nine design principles, including clearly defined objectives and guidance on who should create standards, how they should be developed and what they should contain.

United Kingdom: CMA publishes decision to release retained SME banking undertakings

As reported in the August 2025 edition of this Newsletter, in August this year the Competition and Markets Authority (CMA) consulted on its proposed decision that the limitation on bundling provisions in the 2002 small and medium-sized enterprises banking undertakings (SME Undertakings), which are the only provisions in the undertakings that remain in force, is no longer appropriate and should be released.

Following the consultation, on 1 December 2025 the CMA confirmed that proposed decision and gave notice of the release of the SME Undertakings.

United Kingdom: FCA provides update on access to cash regime review

On 2 December 2025, the Treasury Committee published an update from the FCA on its review of the access to cash regime.

In the update, the FCA states that it will start the review in Q4 2026 (two years after the rules took effect) as part of its commitment to ongoing monitoring of the regime's effectiveness. It will publish the review findings in Q2 2027.

The review will involve a qualitative and quantitative assessment of the regime, but the exact scope and methodology is yet to be determined. The update includes examples of the questions the review will consider and the key quantitative data points that may inform the review.

The FCA acknowledges that there will be some limitations to the review findings. For example, the review will not directly assess cash acceptance, as the FCA's powers relate to access to cash and it does not collect data on, or have oversight of, cash acceptance.

The FCA notes that, in the first year since the rules came into force in September 2024, 121 banking hubs and 93 cash deposit services (such as ATMs and Post Office counters) have opened.

The FCA is currently undertaking targeted work looking at cash access outcomes in rural areas in response to feedback.

United Kingdom: Recent FCA Consumer Duty publications

On 9 December 2025, the FCA published a consultation paper (CP25/37) on ‘Targeted clarifications of Handbook materials’. The consultation is part of the FCA’s Consumer Duty Requirements Review (CDRR). It follows its July 2024 Call for Input (CFI) on its conduct rules, and is part of the workplan announced in its March 2025 Feedback Statement (FS25/2). The FCA reiterates that it wants to simplify its requirements by relying more on high-level rules, while ensuring it continues to support and protect customers. The proposals also support the priorities set out in the FCA’s Strategy 2025-2030.

The FCA is asking for views on a number of proposals including:

• Smaller Firms Guide: The FCA is seeking views on its approach to creating a smaller firms guide and inviting industry views on where firms have an unmet need in understanding its requirements and how to meet this need.
• Clarifying references to Principles 6 and 7: There are proposals to amend references to Principles 6 and 7, now that the Consumer Duty has been introduced. The FCA also considers references to ‘treating customers fairly’ which is rooted in Principle 6 and the treatment of related non-Handbook materials that are still accessible on its website.

The consultation closes on 27 January 2026.

Most of the proposed rule changes would come into force immediately after they are made in the FCA’s policy statement. The FCA anticipates that this will be in Q2 2026.

There is further information on the progress that the FCA has made in delivering its Requirements Review workplan on its website, including its future priorities following engagement with stakeholders.

In addition, on 8 December 2025 the FCA published a statement aimed at clarifying its supervisory expectations to help firms interpret the Consumer Duty where they work together to create products and services. The FCA intends to build on the approach outlined in the statement in 2026, when it plans to review and consult on amendments to the rules.

United Kingdom: Property (Digital Assets etc) Act 2025 comes into force

On 2 December 2025, the Property (Digital Assets etc) Act 2025 received Royal Assent and came into force, completing its passage through Parliament. The new Act confirms the pre-established common law position that a thing is not prevented from being the object of personal property rights merely because it does not fall into a traditional category of personal property. It follows the Law Commission's recommendations regarding clarifications necessary in light of market developments with cryptoassets and other digital assets.

Take a look at this Our Thinking article for more detail. 

South Africa: Central bank publishes position paper on retail CBDC

On 3 December 2025, the South African Reserve Bank (SARB) published a Position Paper and Background Note (Position Paper) on the need for a retail central bank digital currency (CBDC) in South Africa. The paper follows extensive research, technical experimentation and stakeholder engagement.

The SARB concluded that while a retail CBDC is technically feasible and could support innovation and public access to central bank money, there is no compelling case for immediate implementation. The central bank's current priority remains modernising South Africa's payment ecosystem and expanding participation in the national payment system. It will continue to monitor developments and focus on wholesale CBDC applications to ensure readiness if retail CBDC adoption becomes necessary.

The Position Paper also sets out assessment criteria for any future CBDC design, including financial stability, monetary policy transmission and operational resilience, and emphasises that a CBDC should complement existing payment instruments rather than replace them.

Taiwan: Press report indicates first regulated stablecoin expected in 2026

On 3 December 2025, it was reported that Taiwan's authorities expect the island's first regulated stablecoin to launch next year. According to the article, the Financial Supervisory Commission (FSC) is working on a framework to govern issuance and compliance, aiming to ensure that the stablecoin aligns with anti-money laundering and consumer protection standards. The FSC Chair has reportedly told lawmakers that the draft Virtual Assets Service Act has cleared initial cabinet reviews and could pass its third reading in the next session.

The report notes that the FSC has been engaging with industry participants to shape the regulatory approach, which is likely to include licensing requirements and oversight of reserve assets. No official statement or detailed rules have yet been published by the FSC.

Turkmenistan: Press report indicates new law regulating crypto mining and exchanges

On 28 November 2025, it was reported that Turkmenistan has passed legislation to regulate cryptocurrency mining and exchanges.

The report states that the new law introduces licensing requirements for crypto exchanges and mandates registration for mining operations. It also notes that the framework aims to bring digital asset activities under state oversight, reflecting Turkmenistan's cautious approach to financial innovation. While details on enforcement mechanisms and compliance obligations remain unclear, the move signals the government's intent to formalise rules for crypto-related businesses.

According to the report, the Neutral Turkmenistan newspaper has reported that President Serdar Berdymukhamedov had signed the law, and that it will come into force on 1 January 2026.

United States: SEC outlines plans for ‘innovation exemption' to support crypto and fintech development

On 2 December 2025, SEC Chair Paul Atkins revealed in an interview that the agency must ensure its rulebook is “fit for purpose” as it adapts to emerging technologies, including digital assets. Atkins emphasised that the SEC is moving away from “regulation by enforcement” towards a framework that supports innovation while maintaining investor protection.

Atkins explained that the SEC is preparing to introduce an “innovation exemption” designed to allow crypto and fintech firms to launch on-chain products under conditional, supervised relief. This exemption would provide a structured window for experimentation while broader rulemaking develops, reducing compliance costs and accelerating domestic deployment of blockchain-based services. The initiative forms part of “Project Crypto,” an SEC program aimed at modernising legacy rules for digital assets and aligning them with technological developments.

The exemption is expected to include safeguards such as disclosure requirements and investor protection measures, ensuring that firms operate within defined risk parameters. Atkins noted that the approach reflects a shift towards proactive engagement with industry participants, rather than relying on enforcement actions to set regulatory boundaries.

Formal details of the exemption have not yet been published, but reports indicate it could be finalised by the end of 2025 or early 2026, subject to government processes.

United Kingdom: FCA launches stablecoin cohort in Regulatory Sandbox

On 26 November 2025, the FCA announced the creation of a dedicated cohort within its Regulatory Sandbox for firms issuing stablecoins. The initiative aims to allow companies to test stablecoin products under the UK's forthcoming regulatory regime for stablecoins, which is still being developed.

The FCA is inviting applications from firms planning to issue a stablecoin in the UK and those ready to test their products and contribute to policy development. Applications must demonstrate readiness to begin testing, appropriate permissions, resources and a detailed test plan. Successful applicants will be able to trial products in a controlled environment, either with live consumers or firm data, and receive guidance from FCA innovation case officers.

The deadline for applications is 18 January 2026.

In a related speech, FCA executive director David Geale confirmed that a major firm has already joined the cohort and announced in-person policy sprints on stablecoins in March 2026, with expressions of interest opening in January.

United Kingdom: Autumn Budget - DeFi tax and cryptoasset reporting developments

On 26 November 2025, the Chancellor of the Exchequer delivered the 2025 Autumn Budget.

Among the publications and announcements as part of the Budget were:

• HM Treasury’s summary of responses to its consultation on the taxation of decentralised finance (DeFi) arrangements involving the lending and staking of cryptoassets. The consultation explored options for simplifying the tax treatment of DeFi transactions, which currently fall under complex capital gains and income tax rules. Following the consultation, HMRC has continued to have constructive, informal engagement with advisers and industry. As a result, HMRC has been working to develop a potential approach where certain disposals are treated as ‘no gain, no loss’ (NGNL), and which could be extended to include automated market makers. Further details on what this approach might look like are set out in Section 4 to the summary of responses. The informal engagement remains ongoing and the government will continue to assess the merits of this potential approach, and the case for making legislative change to the rules governing the taxation of cryptoasset loans and liquidity pools.
• A government confirmation that UK-based cryptoasset service providers will be required to report information on UK tax resident customers under the OECD’s Cryptoasset Reporting Framework (CARF). Data collection for the first reports will begin on 1 January 2026, with reporting to HMRC scheduled for 2027. This measure aligns the UK with international standards for tax transparency on cryptoassets and is intended to improve compliance and reduce tax evasion risks. Further guidance on implementation is expected in due course.

European Union: ESMA issues statement on MiCA data standards and format requirements

On 28 November 2025, the ESMA published a statement to support the smooth implementation of technical specifications under the Regulation on markets in cryptoassets (MiCA). The statement addresses data standards and format requirements that will apply to cryptoasset service providers and competent authorities, including specifications for order book reporting and record-keeping messages.

ESMA's objective is to ensure consistency and interoperability across the EU by clarifying expectations for data exchange and reporting formats. ESMA also encourages firms and national authorities to begin preparations early, given the complexity of implementing these requirements alongside other MiCA obligations.

Further guidance and technical documentation, including message specifications, have been made available on ESMA's website. 

European Union: ESMA publishes statement on transitional measures under MiCA

On 4 December 2025, ESMA published a statement on the transitional measures in Article 143(3) of the Regulation on markets in cryptoassets (MiCA).

MiCA includes a transitional regime for cryptoasset service providers (CASPs) that offered their services in accordance with applicable law before 30 December 2024. The regime allows those CASPs additional time to transition from complying with existing national regulatory frameworks to complying with MiCA. However, member states have the discretion to not apply the transition regime at all or to reduce its duration.

In the statement, ESMA:

• Reminds firms that some transitional periods have come to an end and the remaining ones will do shortly.
• Notes that market participants have had time to use the transitional periods to engage with national competent authorities (NCAs) in relation to MiCA authorisation. In light of this, ESMA expects CASPs that are not yet authorised under MiCA to:
  • already have implemented orderly wind down plans for the services they provided in member states where the transitional period has ended;
  • have orderly wind down plans in place for the services they provide in member states where the transitional period has not yet ended.

Those plans should be ready to implement ahead of the end of the remaining transitional periods, in case they have not been authorised by then or at all. The plans should allow the CASP to carry out an orderly wind down without causing undue economic harm to clients, e.g. by organising the transfer of cryptoassets to another authorised CASP.

• Reminds NCAs that they are expected to treat "last minute" applications for authorisation under MiCA with considerable caution and assess their compliance with MiCA to the same standard as for any other application. This may include requiring the applicant CASP to wind down its cryptoasset services in one or more member states, or the EU more widely, while the application is assessed. NCAs should also be ready to co-operate with each other to enforce against the unauthorised provision of cryptoasset services.

The statement also includes warnings to investors engaging with cryptoassets, including a reminder to check the ESMA interim MiCA register to confirm whether a CASP entity is authorised to provide cryptoasset services.

Global: BIS update on Basel III implementation - targeted review of prudential standard for banks' cryptoasset exposures

On 19 November 2025, the Basel Committee released an update on Basel III, reiterating the priority to implement Basel III in full and consistently and stating that they have agreed to expedite a review of targeted elements of the prudential standard for banks' cryptoasset exposures. Both the UK PRA and the U.S. Federal Reserve have said that they will not be implementing the rules, which are due to come into force on 1 January 2026, in their current form. Last year the Basel Committee amended its rules to state that cryptoassets using permissionless blockchains would be subject to the most restrictive requirements, with a risk weighting of 1250% for banks. 

Global: BIS publishes report on tokenised money market funds

Further to the Global Digital Finance (GDF), Ownera, EY and Hogan Lovells report on “The Case for Collateral Mobility in Europe & the UK using Money Market Funds (MMFs)” and the IOSCO report on the tokenisation of financial assets, both of which were included in the November 2025 edition of this Newsletter, on 26 November the Bank for International Settlements (BIS) also published a report on tokenisation.

The BIS paper, entitled “The rise of tokenised money market funds”, notes that tokenised MMFs are a fast-growing collateral asset and savings instrument and considers the risks that might arise such as liquidity mismatches.

Global: Klarna to launch dollar-backed stablecoin in 2026

On 25 November 2025, Klarna announced plans to launch KlarnaUSD, a U.S. dollar-backed stablecoin, marking its first major move into digital assets. The token will run on Tempo, a payments-focused blockchain developed by Stripe and Paradigm and is currently in testing with a public mainnet launch scheduled for 2026. KlarnaUSD will initially support internal payment flows, with plans to expand to merchant and consumer use cases.

Klarna said the stablecoin aims to reduce cross-border payment costs and settlement times, positioning it as a faster and cheaper alternative to traditional banking channels. The initiative follows similar launches by PayPal and Stripe and comes as regulators in the U.S. and EU advance new frameworks for stablecoins, including the GENIUS Act and MiCA.

Argentina: Western Union and Pago Fácil roll out prepaid card

On 3 December 2025, it was reported that Western Union and Pago Fácil had announced the launch of a Visa-branded prepaid card in Argentina, developed in partnership with fintech provider Pomelo. The card enables recipients of remittances or loans to access funds through a digital account rather than cash collection, supporting safer and more convenient transactions.

Users can make payments online and in-store, withdraw cash and manage spending without a traditional bank account. The initiative leverages Western Union's extensive local network and aims to promote financial inclusion by reducing reliance on cash.

United Kingdom: ClubManager partners with Worldpay to accelerate expansion

On 3 December 2025, Worldpay announced an expanded partnership with ClubManager, a software provider for sports and fitness clubs, to integrate embedded payments into its UK platform. The integration will enable clubs to manage direct debit and recurring card payments within ClubManager's software, streamlining operations and reducing reliance on multiple providers.

The partnership builds on existing collaboration in Australia and New Zealand and reflects growing demand for embedded financial services in vertical SaaS platforms. 

Brazil: Cumbuca launches to help international firms enter payments market

On 3 December 2025, it was reported that Fintech startup Cumbuca had announced its launch as the first proxy for Brazil's regulated payments ecosystem. The company offers international firms access to the market under its payment initiation licence, providing an alternative to lengthy licensing processes or dependency on third-party providers.

Cumbuca's model allows businesses to build their own infrastructure while Cumbuca manages regulatory compliance. The launch comes as Brazil's financial system, supported by Pix and Open Finance, continues to attract global players seeking to tap into one of the world's fastest-growing digital payments markets.

Europe: Visa launches three new digital wallet projects

On 2 December 2025, Visa announced the rollout of three new digital wallets in Europe, partnering with BBVA, Klarna and Vipps MobilePay and confirmed a pilot with Italy's BANCOMAT for early 2026. The launches follow EU regulatory changes under the Digital Markets Act, which opened Near Field Communication access to third-party wallets on iOS.

BBVA Pay in Spain integrates Visa Token Service for secure transactions, Klarna has enabled tap-to-pay across 14 markets and Vipps MobilePay introduced a Visa co-branded wallet in Norway, with further Nordic expansion planned. Visa said the initiatives aim to increase competition and innovation in mobile payments as consumer adoption of digital wallets accelerates.

United Arab Emirates: Mastercard debuts Access Pass with McLaren and FAB

On 25 November 2025, Mastercard announced the launch of Access Pass in the UAE, a new platform enabling issuers and partners to offer tailored experiences and perks without issuing new cards. The first activation, McLaren Racing Mastercard Pass, gives First Abu Dhabi Bank cardholders access to limited-edition card art, McLaren Plus membership and exclusive events and content.

Access Pass overlays digital designs and benefits onto existing cards via digital wallets, reflecting growing demand for personalised, lifestyle-driven payment experiences. Mastercard plans to expand the program globally in 2026.

Europe: BNP Paribas joins bank consortium aiming to launch euro-backed stablecoin

On 2 December 2025, BNP Paribas announced that it and nine other European banks, including ING and UniCredit, have formed Qivalis, a new company to launch a euro-pegged stablecoin in the second half of 2026. The consortium is applying for an Electronic Money Institution licence from the Dutch central bank and plans to hire up to 50 staff.

Qivalis aims to provide near-instant, low-cost payments and settlements, initially targeting crypto trading use cases. The initiative seeks to counter U.S. dominance in the stablecoin market, where dollar-backed tokens account for the vast majority of volume.

Singapore: Ripple secures expanded payments licence

On 1 December 2025, Ripple announced that the Monetary Authority of Singapore has expanded the scope of its Major Payment Institution licence, allowing the company to offer a broader range of regulated payment services. Ripple can now provide end-to-end cross-border payment solutions using XRP and its RLUSD stablecoin under Singapore's regulatory framework.

The approval strengthens Ripple's position in Asia-Pacific and supports its strategy to deliver institutional-grade settlement tools for banks and fintechs.

Australia: PayPal launches Xoom for international transfers

On 24 November 2025, PayPal announced the launch of Xoom, its international money transfer service, in Australia. The platform enables users to send funds to over 150 countries via bank deposits, mobile wallets, or cash pickup, with real-time tracking and competitive exchange rates.

The rollout leverages PayPal's existing base of 9.5 million active accounts in Australia and aims to capture demand in major remittance corridors such as India, China and the Philippines. 

Latin America & Caribbean: Mastercard launches Agent Pay for cash digitisation

On 3 December 2025, Mastercard announced the launch of Agent Pay, a new solution designed to digitise cash payments in Latin America and the Caribbean. The service enables consumers to pay bills, top up mobile accounts and make other transactions through authorised agents using Mastercard's secure digital infrastructure.

Agent Pay aims to reduce reliance on cash and expand financial inclusion by providing a simple, low-cost entry point for underserved communities. The rollout leverages Mastercard's partnerships with local financial institutions and fintechs to integrate the solution into existing agent networks.

India: Wise introduces multi-currency travel card

On 8 December 2025, Wise announced the launch of its multi-currency travel card in India, allowing users to hold and spend in over 40 currencies at real exchange rates. The card supports international transactions without hidden fees and can be managed through the Wise app, which offers instant currency conversion and spending controls.

Wise said the product targets India's growing outbound travel market and aims to provide a cost-effective alternative to traditional forex cards. The launch follows regulatory approval under India's Liberalised Remittance Scheme and reflects rising demand for transparent, cross-border payment solutions.

Global: Mirakl announces agentic commerce partnership with Stripe

On 11 December 2025 Mirakl, a leading provider of e-commerce and marketplace software solutions, announced that it is partnering with Stripe, the payment processing platform provider. The partnership will enable Mirakl to use Stripe's connections to AI platforms, including OpenAI, to provide secure access to agentic commerce channels for merchants and businesses.

According to the announcement, the partnership is an important step in Mirakl's broader strategy to provide merchants with expanded access to agentic commerce channels. Mirakl plans to continue building the infrastructure and partnerships needed to position merchants at the forefront of AI-driven commerce as the ecosystem evolves.