header-logo header-logo

Debanking: balancing transparency & compliance

223033
David Hamilton on how the UK’s new debanking rules reshape financial services risk management
  • This article considers the intentions and implications of the Payment Services and Payment Accounts (Contract Termination) (Amendment) Regulations 2025.
  • There are two principal changes to the existing Payment Services Regulations framework: the notice period payment firms must give customers prior to terminating services, and the explanations payment firms must give customers for their decisions to terminate services.
  • The compliance requirements on payment firms include customer onboarding and risk assessments, maintaining detailed records and training provisions.

On 28 April 2025, the UK government introduced a draft statutory instrument titled the Payment Services and Payment Accounts (Contract Termination) (Amendment) Regulations 2025 (the amended PSPA Regulations). Despite the prosaic title, the amended PSPA Regulations (if passed) have potentially significant implications for how firms terminate the provision of payment services, commonly referred to as ‘debanking’.

Since Nigel Farage’s public spat with Coutts Bank in 2023, the issue of debanking has drawn sustained public, political and regulatory scrutiny, becoming emblematic

If you are not a subscriber, subscribe now to read this content
If you are already a subscriber sign in
...or Register for two weeks' free access to subscriber content

MOVERS & SHAKERS

Carey Olsen—Kim Paiva

Carey Olsen—Kim Paiva

Group partner joins Guernsey banking and finance practice

Morgan Lewis—Kat Gibson

Morgan Lewis—Kat Gibson

London labour and employment team announces partner hire

Foot Anstey McKees—Chris Milligan & Michael Kelly

Foot Anstey McKees—Chris Milligan & Michael Kelly

Double partner appointment marks Belfast expansion

NEWS
The Ministry of Justice (MoJ) has not done enough to protect the future sustainability of the legal aid market, MPs have warned
Writing in NLJ this week, NLJ columnist Dominic Regan surveys a landscape marked by leapfrog appeals, costs skirmishes and notable retirements. With an appeal in Mazur due to be heard next month, Regan notes that uncertainties remain over who will intervene, and hopes for the involvement of the Lady Chief Justice and the Master of the Rolls in deciding the all-important outcome
After the Southport murders and the misinformation that followed, contempt of court law has come under intense scrutiny. In this week's NLJ, Lawrence McNamara and Lauren Schaefer of the Law Commission unpack proposals aimed at restoring clarity without sacrificing fair trial rights
The latest Home Office figures confirm that stop and search remains both controversial and diminished. Writing in NLJ this week, Neil Parpworth of De Montfort University analyses data showing historically low use of s 1 PACE powers, with drugs searches dominating what remains
Boris Johnson’s 2019 attempt to shut down Parliament remains a constitutional cautionary tale. The move, framed as a routine exercise of the royal prerogative, was in truth an extraordinary effort to sideline Parliament at the height of the Brexit crisis. Writing in NLJ this week, Professor Graham Zellick KC dissects how prorogation was wrongly assumed to be beyond judicial scrutiny, only for the Supreme Court to intervene unanimously
back-to-top-scroll