Code of Conduct for Indirect Access Providers
This voluntary Code of Conduct for Indirect Access Providers has been developed in response to the findings of the Payment Systems Regulator’s (PSR) consultation paper CP14, “A New Regulatory Framework for Payment Systems in the UK”, and its annexes. The consultation was launched in November 2014 in response to industry research into ease of access to UK Payment Systems that highlighted a variety of concerns around the supply of Indirect Access, namely:
- security of supply of Indirect Access, such as the risk that Indirect Access Providers discontinue the supply of Indirect Access;
- the sharing of commercially sensitive information between Indirect Access Providers and Indirect PSPs who are also downstream 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.
The findings of the consultation were published in March 2015 in the form of the PSR’s policy statement PS15/1 and its annexes, which recommended the development of a Code of Conduct to increase confidence in the supply of Indirect Access and lead to improved outcomes for service users.
Current Code Subscribers
The following Indirect Access Providers have subscribed to the Code of Conduct:
- Lloyds Banking Group
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 to whom they provide Indirect Access (Code Beneficiaries.
Who the Code Applies to
An Indirect Access Provider may choose to become a Code Subscriber if it is registered with or authorised by the UK 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 Code Administration on 020 3217 8167 or email
A list of current Code Subscribers is held by the Code Administrator.
An Indirect PSP 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 UK 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.
Publication of the Code and Consultation
The Code of Conduct for Indirect Access Providers is a voluntary Code that has been developed by Payments UK on behalf of the industry, and in association with the industry’s primary Indirect Access Providers – Barclays, HSBC, Lloyds Banking Group and RBS – and in discussion with the Payment Systems Regulator (PSR). Payments UK has also undertaken initial consultation with potential subscribers and beneficiaries of the Code.
Responses to this Consultation will be collated by the Code Administrator and shared with the PSR so it can consider responses alongside its market review into indirect access.
For further information on the Consultation and to share your views on the Code, please visit the Consultation page.