Code of Conduct for Indirect Access Providers

This voluntary Code of Conduct for Indirect Access Providers was developed by the subscribing Indirect Access Providers (IAPs) in conjunction with the Payment Systems Regulator (PSR) to address concerns around the commercial access arrangements they provide to Payment Service Providers (PSPs) requiring Indirect Access to UK Payment Systems. The areas of concern covered:

  • clarity on the contractual arrangements that govern the supply of Indirect Access services used;
  • security of the supply of Indirect Access, such as the risk that Indirect Access Providers discontinue the supply of Indirect Access;
  • ensuring confidentiality of commercially sensitive information shared between Indirect Access Providers and Indirect PSPs who are also competitors;
  • some aspects of the on-boarding and contractual arrangements that govern the supply of Indirect Access; and
  • communication between Indirect Access Providers and Indirect PSPs.

 

An interim Code was initially published on 1st September 2015 followed by a consultation amongst IAPs and Indirect PSPs (IPSPs) in order to consider the effectiveness of the Code and to refine it further (this completed earlier in 2016 and further information on the consultation is provided below).

 

Current Code Subscribers

The following Indirect Access Providers have subscribed to the Code of Conduct:

  • Barclays
  • HSBC
  • Lloyds Banking Group
  • RBS
 

About the Code

The Code sets out standards of best practice for key elements of the commercial arrangements between Indirect Access Providers and Indirect PSPs.

The principal aim of the Code is to improve the experience of Indirect PSPs by clearly setting out the responsibilities of Indirect Access Providers who have subscribed to the Code (Code Subscribers) to Indirect PSPs (IPSPs) to whom they provide Indirect Access (Code Beneficiaries).

 

Code Administration

The Code Administrator is responsibility for administrating all aspects of the Code and this role is currently managed via Payments UK.  If you need more information on the Code, or would like to provide any feedback, please email: code_administration@paymentsuk.org.uk.


Who the Code Applies to

Code Subscribers:

An Indirect Access Provider may choose to become a Code Subscriber if it is registered with, or authorised by, the Financial Conduct Authority for activities that include provision of payment services OR is an EEA-passported Payment Service Provider.

Any Indirect Access Provider wishing to apply to Payments UK to be registered as a Code Subscriber can contact the Code Administrator by emailing code_administration@paymentsuk.org.uk.

 

Code Beneficiaries:

An Indirect PSP (IPSP) that has an arrangement for Indirect Access to one or more in-scope UK Payment Systems with an Indirect Access Provider who is a Code Subscriber may qualify as a Code Beneficiary.

To qualify as a Code Beneficiary, an Indirect PSP must also be registered with, or authorised by, the Financial Conduct Authority for activities that include provision of payment services OR is an EEA-passported Payment Service Provider.

IPSPs should contact their Indirect Access Provider if they wish to review their indirect access arrangements.

 

Code Consultation and Feedback

Following publication of the Interim Code in September 2015, Payments UK in its role as the Code Administrator undertook a consultation with potential subscribers and beneficiaries focusing on the effectiveness of the Code.

Payments UK, working with the four main subscribing IAPs, have reviewed the consultation responses and will be revising the Interim Code for publication later in 2016. 

Consultation responses have also been shared with the PSR so it could consider industry views alongside its market review into indirect access. Their final report was published in July 2016.

For information on the Consultation and to view responses, please visit the Consultation page.