Non-banks are having an increasing role in payments, including the provision of payments services directly to end-users. Despite this increasing role, many of them are still not accepted as direct participants of key payment infrastructures, which often leads to limited or null interoperability in the services/products they offer. Moreover, being able to use key payment infrastructures at a reasonable cost and with appropriate service levels is an important element underlying a competitive payments market.
The operators of these payment infrastructures should adhere to international standards and best practice and establish risk-based and objective access criteria, and ensure that any PSP that wishes to gain direct access and meets such criteria is able to join as a direct participant.
Still, for many non-bank PSPs gaining direct access may not be feasible due to the investments they would need to make in order to fulfill the infrastructure’s access criteria. In such cases indirect access mechanisms may be capable of providing these PSPs with suitable payment services. However, in certain cases indirect access may not be as effective, for example if charges applied by the principal (an entity that is a direct participant in the infrastructure) are excessive relative to the costs it itself incurs for using the system, or if the criteria set by the principal for opening accounts and providing payment services to customer PSPs are disproportionate.
Payment system regulators, in particular the central bank as the payment system overseer, should ensure that all PSPs are able to gain fair access to payment services, including those for which direct access is not financially feasible and need to access the services through a principal.
Effective access to payment infrastructures may also be hampered if there are barriers to accessing the telecommunications networks serving those infrastructures. Telecommunications regulators may also have a role to play in markets where it has been observed that MNOs that are involved in the payments business restrict in some form the access to other PSPs to the mobile telecommunications network that these MNOs operate.
The main purpose of this report is therefore to discuss access-to-payment-infrastructures issues around the world, and how these can affect the development of safe, efficient, interoperable and financially inclusive payment services.
The author of this Technical Report is Jose Antonio Garcia. Contributions were received from the members of the FG DFS Interoperability Working Group and in particular from Ghassan N. Abu Shihab, Niyi Ajao, Lara Gidvani and Thomas Lammer. The Technical Report was reviewed by the Focus Group Digital Financial Services. Thomas Lammer provided the overall guidance for this project.