Introduction
South Africa's National Payment System is being rebuilt. The SARB's modernisation programme is opening participation to authorised fintech payment providers, replacing the industry's governance, and building shared infrastructure for instant payments, identity, and fraud prevention. The decisions taken over the next two years will set the shape of the system for decades.
ASAPP's members serve the consumers, spaza shops, and merchants that the traditional system has served least well, and these positions set out what we believe the modernisation must deliver for them: a system any capable institution can join, rails that reach every account and every counter, costs that keep falling, and infrastructure every participant can trust.
We hold these positions across four pillars. Each opens with the outcome we are working towards, followed by the specific positions we will advance with the SARB, the schemes, and the industry through 2026/2027.
These positions are intended to establish ASAPP's strategic policy direction for 2026/2027. They identify the outcomes ASAPP wants to pursue, rather than prescribe a final technical or implementation model. Detailed options and implementation mechanisms will be developed through the relevant Strategic Delivery Platforms, informed by member and specialist input, and brought back for consideration and approval where appropriate.
PILLAR 02
Infrastructure & Payment Rails
PILLAR 03
Cost of Payments & Competition
PILLAR 04
Identity, Data, Fraud & Cyber
PILLAR 01
Market Access
ASAPP envisions a national payment system that is open to any institution able to serve customers well, whatever its size or origin. South Africa has a growing community of fintech payment providers reaching customers and merchants that the traditional system has served less closely, and the South African Reserve Bank's (SARB) modernisation programme sets out to bring those providers into the system as full participants. In that system an authorised fintech payment provider can issue e-money, acquire merchants, initiate payments, and clear and settle in its own name, on published criteria and at a cost it can meet from its own resources, and it holds a vote in the bodies that write the rules it will follow. The positions below support the authorisation framework, the exemption notice, and the National Payment System (NPS) Bill as the instruments that deliver this, and set out how each can deliver it in full.
These positions represent ASAPP's desired strategic outcomes and policy direction. They are not intended to prescribe specific technical, commercial or implementation solutions. Detailed implementation options will be evaluated and developed through the relevant Strategic Delivery Platforms and brought back to members where appropriate.
1.1 Direct participation in clearing and settlement
ASAPP supports direct participation by appropriately authorised fintech payment providers in relevant clearing and settlement arrangements on objective, transparent and proportionate terms. The objective is to ensure that qualifying fintech payment providers can participate effectively in core payment infrastructure without unnecessary structural dependencies. Pricing for direct participation should be transparent, cost-reflective, and non-discriminatory, with no premium or structural barrier applied solely because of the category of participant. Fee schedules should be published and reviewed on a stated cycle. Any authorised institution that meets the published criteria should be onboarded within a predictable period, subject to a standardised onboarding and approval procedure.
Rationale and Intended Outcome
Direct participation can reduce unnecessary intermediation, cost and dependency on sponsoring institutions, while giving qualifying fintech payment providers greater control over their payment operations.
The intended outcome is a clear and commercially viable route to clearing and settlement for appropriately authorised participants that meet the applicable requirements.
1.2 Sponsorship as an access route
ASAPP supports sponsorship under the authorisation framework. Sponsorship works best for both parties when its terms are known in advance, so that a new entrant can plan its launch and a sponsor can offer a standard service. We would support standard sponsorship terms published by the SARB or the scheme: a template agreement, a maximum onboarding period, and open terms for any authorised institution that meets the published criteria. Detailed contractual and risk terms should be agreed between the sponsor and the sponsored participant within this framework. Terms of this kind give every new entrant a clear path into the system and provide sponsors with a clear framework within which to offer the service.
Rationale and Intended Outcome
Sponsorship remains an important access route for participants that choose, or need, to operate through a sponsor. Clear and consistent sponsorship terms can reduce uncertainty, delays and barriers to market entry.
The intended outcome is a predictable and fair sponsorship framework that remains available irrespective of the size of the institution and complements, rather than restricts, direct participation.
1.3 Authorisation requirements scaled to activity
ASAPP supports the activity-based authorisation framework and the exemption of payment activities from the business of a bank. The framework works best when each requirement matches the risk the activity carries. The framework should distinguish funds held temporarily for onward settlement to merchants from funds representing e-money balances. The applicable requirements should take account of the purpose and ownership of the funds, the period for which they are held. The industry must be consulted on the proposed capital, safeguarding, governance, and reporting thresholds, and their practical effect, before they are finalised. Capital, safeguarding, governance and reporting requirements should be set by the activity performed and the volumes and balances handled, with the thresholds published, so that each participant meets requirements appropriate to its own scale and risk profile. We would support a published service standard for authorisation decisions and a public register of authorised, designated and registered institutions showing the activities each may perform.
Rationale and Intended Outcome
Regulatory requirements should reflect the nature, scale and risk of the payment activity being undertaken. A proportionate framework protects the integrity of the payment system without imposing requirements that unnecessarily restrict participation or innovation.
The intended outcome is a transparent authorisation framework in which participants understand the requirements applicable to their activities and can plan accordingly.
1.4 Continuity of trading through the transition
ASAPP supports transition arrangements that allow existing participants that submit complete applications within the prescribed period to continue the activities permitted under their current registrations while their applications are considered. This should remain subject to ongoing compliance with existing obligations and any reasonable supervisory conditions. Where an application is not determined within the published period, the transitional recognition should continue until the SARB makes its decision.
Rationale and Intended Outcome
The move to the new authorisation framework should not unnecessarily disrupt existing payment services or create uncertainty for providers, merchants and customers while applications are being considered.
The intended outcome is an orderly transition that provides continuity for existing participants, clear timelines and sufficient certainty for the industry to prepare for the new framework.
1.5 Fintech payment provider membership of the bodies that write the rules
ASAPP supports the SARB's decision to place rule-making with the SARB and with licensed schemes. Fintech payment providers should have meaningful representation and, where appropriate, voting participation in scheme governance bodies, committees and industry structures whose rules or decisions materially affect them. Meaningful representation ensures that their operational and commercial perspectives are considered when those rules are developed or amended. Consultation rights should be clearly established within the applicable regulatory and governance frameworks and should continue notwithstanding changes to the relevant industry structures.
Rationale and Intended Outcome
Fintech payment providers are directly affected by the rules, standards and governance decisions that determine how they participate in the National Payment System. Meaningful representation is therefore important to ensure that their operational and commercial perspectives are considered when those rules are developed or amended.
The intended outcome is for appropriately authorised fintech payment providers to have effective representation and voting participation in relevant governance and rule-making structures, together with meaningful consultation rights on matters that materially affect them.
PILLAR 02
Infrastructure and Payment Rails
ASAPP envisions digital payments that are as easy to use and as widely accepted as cash, so that every South African can pay and be paid instantly, from any account or wallet, at any shop, at a cost that makes sense for small purchases. Brazil and India have shown that a country can reach this within a few years through central bank leadership, universal participation, and a single set of standards, and South Africa has each of those in place. PayShap is the rail on which this will be built, and ASAPP envisions it as the everyday way to pay: recognised under one brand, reachable from every transactional account and wallet, accepted at every terminal and every QR code, and connected to cash at every access point. The positions below set out how participation, brand, acceptance, proxies, and stores of value can each be developed to reach that point.
These positions represent ASAPP's desired strategic outcomes and policy direction. They are not intended to prescribe specific technical, commercial or implementation solutions. Detailed implementation options will be evaluated and developed through the relevant Strategic Delivery Platforms and brought back to members where appropriate.
2.1 Mandatory PayShap participation and feature parity
ASAPP supports broad and interoperable participation in South Africa's real-time payment infrastructure, with the core PayShap functionality available consistently across participating institutions, channels and customer segments. Participation and functionality should support PayShap becoming a widely accessible and widely usable national payment capability.
PayShap can only achieve meaningful scale if customers can use it consistently across institutions and channels. Fragmented participation, functionality or customer experience limits network effects and reduces its usefulness as a national payment capability.
The intended outcome is broad reach and consistent functionality across the ecosystem so that consumers and businesses can use PayShap regardless of which participating provider they use.
2.2 PayShap as a common brand
ASAPP supports a coordinated national education and awareness campaign, run jointly by the SARB, PayInc and the industry, that establishes PayShap as a common brand that consumers and merchants recognise and understand across participants. Participants should support a sufficiently consistent customer experience so that customers understand when and how they are using PayShap.
Rationale and Intended Outcome
A payment capability is more likely to achieve broad adoption where consumers and merchants recognise it and understand how it works regardless of the provider through which it is accessed.
The intended outcome is greater consumer and merchant awareness, trust and adoption of PayShap as a recognised national payment capability.
2.3 Co-badging and least-cost routing
ASAPP supports PayShap being capable of acceptance through existing and emerging payment acceptance infrastructure, including POS and QR infrastructure, where appropriate. The acceptance environment should support interoperability and allow eligible transactions to make use of the most appropriate payment rail, subject to applicable regulatory, security and customer-protection requirements.
Least-cost routing should not be limited to PayShap. The same principle applies to card transactions, where the routing decision and the cost of that routing currently sit with different parties. ASAPP supports routing arrangements across PayShap, card and any other rail capable of supporting choice of route being governed so that the party bearing the costs has the ability to select the most appropriate route for these transactions.
Rationale and Intended Outcome
Requiring merchants and customers to adopt entirely separate acceptance infrastructure for each payment rail can increase cost and slow adoption. Making appropriate use of existing acceptance infrastructure may allow PayShap to reach merchants more quickly and efficiently.
In card payments in South Africa, the issuer controls the routing decision, while the scheme fees and associated costs of that routing are borne by the acquirer. Issuers are commercially incentivised by the schemes to route transactions in ways that do not reflect the lowest overall system cost, because the party choosing the route is not the party bearing it. This misalignment removes the competitive discipline that routing choice is meant to create and is the same fragmentation problem this position already identifies for PayShap acceptance.
The intended outcome is broad and practical merchant acceptance and routing efficiency across all payment rails (not PayShap alone), with routing decisions governed so that the party bearing the costs can decide the routing most suitable to them, driving greater competition between available payment rails and card schemes.
2.4 Fintech payment provider acquiring on PayShap
ASAPP supports appropriately authorised fintech payment providers being able to onboard and service merchants for PayShap acceptance on objective, transparent and proportionate terms, without unnecessary structural dependencies. Rules relating to merchant acceptance should apply consistently to participants performing equivalent activities. Scheme-level rules should address refunds, reversals, disputes, settlement timing and finality, and responsibility for erroneous, fraudulent, or disputed payments. Comparable outcomes should apply to banks and fintech payment providers performing the same activity.
Rationale and Intended Outcome
Fintech payment providers already play an important role in serving merchants, including underserved merchants. Their ability to participate meaningfully in PayShap merchant acceptance can materially increase the reach and adoption of the service.
The intended outcome is a competitive merchant-acceptance environment in which appropriately authorised providers can participate on equivalent terms and merchants have a broader choice of provider.
2.5 Proxy portability and confirmation of payee
ASAPP supports payment proxy portability and confirmation-of-payee capabilities being available across eligible participants on objective and appropriately governed terms. Consumers and merchants should be able to transfer their payment proxies and, where applicable, merchant identifiers linked to QR acceptance between providers without unnecessary barriers or loss of continuity.
The intended outcome is greater customer mobility, continuity of payment identifiers and stronger safeguards against fraud and misdirected payments.
Rationale and Intended Outcome
A payment proxy becomes increasingly valuable as customers and businesses begin using and storing it as a payment address. If that proxy cannot move with the customer, it can become a barrier to switching providers. Confirmation of payee can also reduce payment errors and fraud by giving customers greater certainty about the recipient of a payment.
The intended outcome is greater customer mobility, continuity of payment identifiers and stronger safeguards against fraud and misdirected payments.
2.6 QR+ as the single acceptance standard
ASAPP supports QR+ being implemented as interoperable acceptance infrastructure that can be accessed by appropriately authorised issuers, acquirers and payment providers on objective, transparent and proportionate terms. The standard and participation arrangements should promote interoperability and avoid unnecessary barriers or preference for a particular category of participant or payment rail.
Rationale and Intended Outcome
Fragmented QR acceptance requires merchants to support multiple solutions and customers to determine which application or QR standard will work at a particular merchant. The intended outcome is a simpler and more interoperable QR acceptance environment in which merchants can accept payments across participating providers and rails without unnecessary duplication.
2.7 Cash-in and cash-out
ASAPP supports making cash more affordable to access, extending the reach of cash infrastructure, and improving financial inclusion without prescribing a specific mechanism for achieving these objectives. Appropriately authorised bank and fintech payment providers should be able to participate in cash-in and cash-out services and in shaping any programme developed to advance these objectives subject to proportionate regulatory and risk-management requirements. Where merchants act as cash access points, the applicable framework should clarify their agency status and the requirements relating to customer checks, record keeping, liquidity, security, fees, and liability.
Rationale and Intended Outcome
Affordability, coverage and inclusion in cash access can be advanced through several possible mechanisms and targeted measures, such as scheme-fee and routing reform, as well as a handful of additional levers available to the regulator.
Cash remains an important part of the South African economy, particularly for consumers and merchants that are not yet fully served by digital payment channels. The extended cash infrastructure can be maintained, expanded and coupled with digital adoption through well-considered, incremental changes, rather than through the cost, risk and disruption of restructuring cash infrastructure that already serves the large majority of the country well. A collaborative approach by banks and fintech payment providers will drive innovative and interoperable solutions where customers can move easily between cash and digital value.
The intended outcome is broader access to digital payments while maintaining practical links to cash for customers and communities that continue to depend on it. Therefore, it is imperative that the SARB's cash objectives are pursued through the lowest-cost, lowest-risk mechanisms available, preserving the competition, redundancy and innovation that existing bank and fintech payment provider cash infrastructure already provides rather than through a single prescribed model adopted before its costs, risks and alternatives have been properly considered.
2.8 Interoperability of Stores of value
ASAPP supports interoperable stores of value, enabling appropriately authorised wallets and payment accounts to send and receive value across providers and payment networks, subject to appropriate regulatory and risk-management requirements.
Rationale and Intended Outcome
Closed stores of value can limit a customer's ability to transact outside a particular provider or ecosystem and can reduce customer choice and competition.tor.
The intended outcome is for customers to be able to pay and receive payments across providers more easily, while allowing different providers and stores of value to compete on service, price and functionality rather than on closed network effects.
2.9 Government participation in modern payment infrastructure
ASAPP supports the participation of government institutions in interoperable digital payment systems. Public-sector collections and disbursements should advance the objectives of financial inclusion, interoperability, competition and customer choice while supporting broader adoption of digital payments across the economy.
Rationale and Intended Outcome
Government is one of the country's largest originators and recipients of payments. The payment choices made for public-sector collections and disbursements can therefore materially influence adoption, accessibility and the development of payment infrastructure.
The intended outcome is for public-sector payment activity to support an open and interoperable digital-payment ecosystem and contribute to broader financial inclusion and adoption.
2.10 Regional and cross-border interoperability
ASAPP supports greater interoperability between South Africa's payment system and regional payment networks. Cross-border payments should become more accessible, affordable and efficient for consumers and businesses while maintaining appropriate standards for security, financial integrity and regulatory compliance. Implementation should address exchange-control treatment, the responsibilities of Authorised Dealers, balance-of-payments reporting, foreign-exchange disclosures, anti-money laundering requirements, and sanctions screening.
Rationale and Intended Outcome
Cross-border payments remain important for individuals, merchants and businesses operating across South Africa and the wider region. Greater interoperability between payment systems can reduce friction and improve the accessibility and efficiency of these payments.
The intended outcome is a more connected regional payment environment in which cross-border payments become easier and more affordable while maintaining appropriate regulatory, financial-integrity and security safeguards.
PILLAR 03
Payment Economics
ASAPP envisions a payment system in which digital payments cost less than cash for the people and businesses that use them, and in which that cost keeps falling as more of the economy moves to digital. Lower and clearer costs let a spaza shop accept a card or a QR payment for a R20 sale, let a consumer pay digitally without thinking about the fee, and let a new provider compete on its product. The cost of a digital payment is made up of several parts, interchange, card scheme fees, scheme pricing on PayShap, and the fees charged for access to shared infrastructure, and each is set in its own way today. The positions below set out how each part can be set on a published basis, reviewed together, and passed through to merchants and consumers in price.
These positions represent ASAPP's desired strategic outcomes and policy direction. They are not intended to prescribe specific technical, commercial or implementation solutions. Detailed implementation options will be evaluated and developed through the relevant Strategic Delivery Platforms and brought back to members where appropriate.
3.1 Interchange
ASAPP supports a reduction in interchange on consumer card transactions and an evidence-based methodology for determining interchange rates. The methodology should take account of the cost to merchants of accepting digital payments, the impact of interchange on merchant acceptance and the transition from cash to digital payments. Interchange should be transparent, regularly reviewed and support competition, financial inclusion and broader digital-payment adoption.
Rationale and Intended Outcome
Interchange forms a material component of the cost of card acceptance and can influence whether merchants are able or willing to accept digital payments. The level and methodology should therefore consider the broader objective of expanding digital-payment acceptance rather than focusing only on issuer cost recovery.
The intended outcome is a sustainable interchange framework that lowers barriers to digital-payment acceptance, promotes competition and supports the continued transition from cash to digital payments.
3.2 Card scheme fees
ASAPP supports greater transparency in the fees charged by international card schemes and their inclusion in any assessment or regulatory review of the overall cost of card acceptance. Scheme fee schedules and material payments, incentives or rebates that affect the overall economics of card transactions should be sufficiently transparent to enable the full cost of card acceptance to be understood and assessed.
This transparency should extend to how scheme fees interact with routing. Because the party that selects the network a card transaction is routed over (the issuer) is not the party that pays the resulting scheme fee (the acquirer), scheme fees are not subject to the ordinary competitive discipline that routing choice would otherwise provide. ASAPP supports regulatory oversight of scheme fees — including the ability to benchmark, limit or cap fees shown to be disproportionate to the cost of the service provided — as a necessary complement to transparency alone.
Rationale and Intended Outcome
Interchange represents only one component of the cost of accepting card payments. Scheme fees and related commercial arrangements may also materially affect the amounts ultimately borne by acquirers and merchants. Reviewing interchange in isolation may therefore provide an incomplete picture of the overall cost of card acceptance.
The intended outcome is greater transparency across the full card-payment cost stack so that pricing, competition and regulatory interventions can be assessed on the basis of the total economic cost of card acceptance.
Transparency alone does not constrain a fee that the party bearing it has no ability to influence. As set out in relation to card routing more broadly, the issuer's routing decision determines which scheme fee applies, while the acquirer and, ultimately, the merchant bear its cost — removing the mechanism that would normally discipline scheme pricing. Without a regulatory backstop, scheme fees can rise independently of any change in the underlying cost or value of the service.
The intended outcome is greater transparency across the full card-payment cost stack, together with regulatory oversight — including benchmarking and, where warranted, caps — so that scheme fees are constrained by regulation where routing and competition cannot constrain them, and pricing, competition and regulatory interventions can be assessed on the basis of the total economic cost of card acceptance.
3.3 PayShap pricing
ASAPP supports the SARB's objective that PayShap should be affordable and capable of supporting widespread adoption, particularly for low-value payments. Low-value PayShap transactions should be free to consumers, participant pricing should be transparent, and fees for access to the service should be set at a level that supports broad participation and adoption. Merchant pricing should be transparent, and the funding model should be published and should avoid transferring a disproportionate share of the cost to merchants or other participants.
Rationale and Intended Outcome
PayShap is intended to provide a practical digital alternative to cash. If consumers or participants face pricing that makes low-value transactions uneconomical, this may limit adoption and reduce PayShap's ability to become an everyday payment method.
The intended outcome is a pricing model that encourages consumers, merchants and payment providers to use PayShap at scale while remaining sustainable for the infrastructure and participants supporting the service.
3.4 Cost of access to infrastructureap
ASAPP supports access to payment services and shared payment infrastructure on objective, transparent and proportionate pricing terms. Pricing should not create unnecessary barriers to entry, participation, competition or innovation.
ASAPP supports published and transparent fee schedules covering all relevant payment services and access to shared payment infrastructure, including, inter alia, scheme participation, payment clearing house system operator services, clearing and settlement services, QR+ participation and registry access, PEMKey issuance and verification, certification and other payment-related infrastructure and services. Equivalent activities should be subject to transparent and consistent pricing irrespective of the category of participant accessing or performing the service.
Rationale and Intended Outcome
Access to shared infrastructure is a necessary cost of participating in the payment system. Where fees are unclear, disproportionate or applied differently to participants performing equivalent activities, they can create barriers to entry and distort competition.
Transparent fee schedules allow existing and prospective participants to understand the cost of participation, plan their business models and assess whether they are being treated consistently with comparable participants.
The intended outcome is a payment ecosystem in which the cost of accessing essential payment infrastructure is predictable, proportionate and competitively neutral, allowing participants to compete on the quality, price and innovation of their services rather than on their ability to absorb infrastructure-access costs.
PILLAR 04
Identity, Data, Fraud & Cyber
ASAPP envisions a payment system that people trust, in which every customer is known once and recognised everywhere, every payment goes to the person it was meant for, and every institution works from the same intelligence and the same rules to prevent fraud. Trust of this kind lets a first-time user of a digital wallet keep using it, and what lets a customer move between providers with confidence. The modernisation programme is building the shared capabilities that make this possible, a reusable identity credential, a central fraud capability, and confirmation of payee, and it has adopted a digital public infrastructure model in which data sharing is the third service alongside identity and payments. The positions below set out how each of these capabilities can be made available to every participant on the same terms, and how open finance can follow from them.
These positions represent ASAPP's desired strategic outcomes and policy direction. They are not intended to prescribe specific technical, commercial or implementation solutions. Detailed implementation options will be evaluated and developed through the relevant Strategic Delivery Platforms and brought back to members where appropriate.
4.1 Shared fraud intelligence
Banks and appropriately regulated fintech payment providers should be able to contribute to, share and access fraud intelligence and fraud-prevention capabilities on an equitable and appropriately governed basis. Participants performing comparable payment activities should have appropriate access to relevant fraud intelligence and capabilities, subject to proportionate governance, privacy, security and information-sharing requirements.
ASAPP supports the development of shared fraud capabilities that enable timely reporting, information sharing and effective fraud detection across the payments ecosystem. The information-sharing framework should define the lawful basis and permitted purposes for sharing, data-quality requirements, correction and appeal processes, retention periods, and the treatment of information shared in good faith.
Rationale and Intended Outcome
Fraud frequently moves across institutions and payment channels, meaning that information held by one participant may be relevant to preventing losses elsewhere in the ecosystem. Restricting access to fraud intelligence can leave some participants unable to identify risks that are already known to others.
The intended outcome is a more coordinated payments ecosystem in which relevant participants can contribute to and act on shared fraud intelligence, enabling earlier detection of fraud, faster intervention and better protection for customers and the payment system as a whole.
4.2 Fraud liability
ASAPP supports a consistent and transparent framework governing responsibility for payment fraud and related losses across the payments ecosystem. The allocation of responsibility should take account of the respective roles of participants, the controls reasonably available to them and their ability to prevent, detect or respond to the fraud. Customers should receive appropriate and consistent protection irrespective of the type of payment provider they use. The framework should expressly address authorised push payment fraud, payment errors, misdirected payments, and the effect of a customer proceeding after receiving a relevant warning or verification prompt.
Rationale and Intended Outcome
Uncertainty regarding responsibility for fraud can lead to inconsistent customer outcomes and disputes between participants regarding who should bear a loss. A clear framework also creates appropriate incentives for all participants to invest in fraud-prevention and detection controls.
The intended outcome is greater certainty for customers and industry participants, consistent treatment of comparable fraud events and an allocation of responsibility that reflects each participant's role and ability to prevent or mitigate the loss.
4.3 PEMKey and digital financial identity
ASAPP supports PEMKey and other shared digital financial identity capabilities that enable secure and reusable customer identification and verification across the payments ecosystem.
Appropriately authorised participants should be able to access and participate in these capabilities on objective, equitable and transparent terms. Where PEMKey or another recognised digital identity capability satisfies the applicable verification requirements, the regulatory framework should enable participants to rely on that verification without unnecessary duplication.
Pricing for access, issuance and verification should be transparent and applied consistently to participants performing equivalent activities. The framework should define responsibility for inaccurate or outdated information and provide clear processes for correction, revocation, and re-verification. It should also cover the identification and verification of legal persons, directors, authorised representatives, and beneficial owners.
Rationale and Intended Outcome
Customer identification and verification are repeated across institutions and can create material cost and friction for both providers and customers. Trusted reusable digital identity capabilities have the potential to reduce duplication while improving the quality and consistency of customer verification.
The intended outcome is a trusted digital identity framework that supports easier onboarding and switching, reduces unnecessary duplication and cost, strengthens fraud prevention and enables appropriately authorised participants to make use of shared identity infrastructure on equitable terms.
The intended outcome is a trusted digital identity framework that supports easier onboarding and switching, reduces unnecessary duplication and cost, strengthens fraud prevention and enables appropriately authorised participants to make use of shared identity infrastructure on equitable terms.
4.4 Open finance and customer control of financial data
ASAPP supports the development of an open finance framework in which customers have effective control over their financial information and can authorise secure access to, and portability of, that information between eligible service providers.
Appropriately authorised participants should be able to access relevant financial data and payment-initiation capabilities on objective, transparent and non-discriminatory terms, subject to customer consent and appropriate privacy, security, data-protection and regulatory safeguards.
Standards should promote interoperability and avoid unnecessary barriers to participation or customer switching. The framework should include common API and availability standards, transparent accreditation requirements, appropriate reciprocity between participants, and clear responsibility for consent failures, misuse of customer information, and inaccurate or incomplete data.
Rationale and Intended Outcome
Financial data is increasingly important to the ability of providers to offer competitive and innovative financial services. Where customers cannot readily make their information available to another provider, established institutions may retain an advantage simply because they hold the customer's historical data.
Giving customers meaningful control over their financial information can make it easier to switch providers, access new services and authorise trusted third parties to act on their behalf.
The intended outcome is a secure and interoperable open-finance environment that increases customer choice and mobility, supports competition and innovation, and ensures that the customer remains in control of how their financial information is used.
4.5 Cyber and operational resilience
ASAPP supports high and proportionate standards of cyber and operational resilience across the payments ecosystem. Critical payment infrastructure and services should be secure, reliable and resilient, with appropriate arrangements for risk management, incident response, recovery and business continuity.
Standards should apply consistently to participants performing comparable activities, taking account of the nature, scale and risk of the services being provided. The framework should also address third-party, cloud, and concentration risk and provide for shared resilience testing. Critical shared services should have tested fallback arrangements where their failure could disrupt essential payment or verification services.
Rationale and Intended Outcome
The increasing interconnectedness and digitisation of the payment system means that operational or cyber incidents affecting one participant or shared service can have consequences across the broader ecosystem. Resilience therefore depends not only on individual institutions, but also on the security and reliability of shared infrastructure and connections between participants.
The intended outcome is a payment ecosystem that can prevent, withstand, respond to and recover from cyber and operational disruption while maintaining confidence in critical payment services.