Code of Conduct for Indirect Access Providers

Code of Conduct for Indirect Access Providers


This voluntary Code of Conduct for Indirect Access Providers has been developed by the subscribing Indirect Access Providers (IAPs) in consultation with the Payment Systems Regulator (PSR) to address concerns around the commercial access arrangements they provide to Payment Service Providers (PSPs) requiring Indirect Access Services to UK Payment Systems.

Pay.UK, in its role as Code Administrator along with the IAPs and PSR have reviewed the Code in light of the recent PSD2 regulation. The enhanced version of the Code reflects on the PSD2 powers relating to indirect access to designated payment systems. 


Earlier versions of the Code 

An interim Code was published in 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. The consultation completed earlier in 2016, resulted in an enhanced version of the Code published in September 2016 and reflects the main themes emerging from consultation feedback: specifically to provide greater clarity, revisions have been made to the Introduction, terminology used and on the scope and purpose of the Code.  

Further information on the Code is provided below.


Current Code Subscribers

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

  • Barclays
  • ClearBank
  • HSBC
  • Lloyds Banking Group
  • RBS

Since the Code’s launch in 2015 subscribing IAPs have taken steps to demonstrate alignment with the Code commitments and following the introduction of the revised Code, they are committed to adhering to its standards of best practice.


Code Administration

The Code Administrator  is responsible for administrating all aspects of the Code and this role is currently managed via Pay.UK. The Code Administrator is responsible for reviewing the effectiveness of the Code through compliance monitoring, engaging with stakeholders and the Payment Systems Regulator (PSR) and through an annual self-certification process. Monitoring also includes seeking feedback from interested stakeholders via a new Code Consultative Group.

If you need more information on the Code, or would like to provide any feedback, please email: 

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 principle aim of the Code is to improve the experience of Indirect PSPs (IPSPs) by clearly setting out the responsibilities of Indirect Access Providers who subscribed to the Code. Specifically, the Code is designed to meet the requirements of IPSPs for:

  • clarity on the contractual arrangements that govern the supply of Indirect Access Services they receive;
  • security of the supply of Indirect Access;
  • confidentiality of commercially sensitive information shared with IAPs;
  • support in establishing Indirect Access and in switching between providers; and
  • appropriate and timely communication between IAPS & IPSPs regarding the availability of services and planned changes.

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 Pay.UK to be registered as a Code Subscriber can contact the Code Administrator by emailing


Code Beneficiaries:

A Code Beneficiary is an Indirect PSP (IPSP) that has an agreement for Indirect Access Services to one or more In-Scope Regulated Payment Systems with an Indirect Access Provider who is a Code Subscriber.

To qualify as a Code Beneficiary, an Indirect PSP must also be:

  • registered with or authorised by the UK Financial Conduct Authority or is an EEA-passported PSP for activities that include provision of payment services; and
  • using Indirect Access Services to provide its customers with eligible payment services.

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