Payment acquiring in the UK is regulated by the Financial Conduct Authority (FCA), Payment Systems Regulator (PSR), and international card schemes. Businesses processing card payments must navigate authorization requirements, capital thresholds, and technical compliance standards to operate legally in this space.
April 04, 2025
This guide outlines the regulatory framework for payment acquirers, covering FCA authorization, safeguarding obligations, AML compliance, and scheme membership requirements. It provides essential information for businesses seeking to enter the payment acquiring market or work with established acquirers, detailing both initial licensing steps and ongoing compliance responsibilities.
Who Regulates Payment Acquirers in the UK
Payment acquiring is a regulated activity in the UK, meaning businesses that provide this service must meet strict legal and compliance standards before they can operate. Three key entities are involved in regulating and overseeing acquirers.
Financial Conduct Authority (FCA)
The Financial Conduct Authority (FCA) regulates UK financial services firms. If your firm intends to act as an acquirer—helping merchants accept card payments—you must obtain authorisation under the Payment Services Regulations 2017. Acting as a payment acquirer without FCA authorisation constitutes a criminal offence under UK law.
Payment Systems Regulator (PSR)
While the FCA regulates individual firms, the Payment Systems Regulator (PSR) oversees the systems enabling UK payments, such as Bacs, Faster Payments, CHAPS, and card networks. The PSR ensures that these systems remain competitive and accessible.
This affects acquirers who must use settlement networks and clearing infrastructure or gain scheme access through banking or related services. If you plan to clear and settle transactions via a major system or through an integrator, you must meet the PSR's access requirements—though access terms may not always be favourable.
Card Schemes (Visa, Mastercard)
Beyond UK regulators, acquirers must engage with international Card Schemes such as Visa and Mastercard. Though not governmental bodies, these schemes enforce strict membership and scheme compliance standards for routing card transactions through their networks.
You will need either direct membership or a sponsorship agreement with a principal member. Compliance obligations cover transaction processing, fraud monitoring, technical certification, and dispute handling.
Key UK Legislation Governing Payment Acquirers
The legal foundation for payment acquiring in the UK is built on several key pieces of legislation. These laws define what acquiring activity is, when it becomes regulated, and what obligations apply to businesses involved in processing card payments.
Payment Services Regulations 2017 (PSRs 2017)
The Payment Services Regulations 2017 (PSRs 2017) relate to the legislative provisions which control payment services within the UK. These are the regulations that implement the European Union's Second Payment Services Directive (PSD2), which applies to the UK post-Brexit.
The PSRs 2017 stipulate that acquiring of payment transactions is a regulated payment service. Therefore, any company working with merchants to effect card payment for goods and services to the consumer—and settling that payment in conjunction with card schemes—is engaging in a regulated payment service.
The PSRs 2017 allow for:
The application process to become a licensed Payment Institution (PI)
Capital requirements based on business structure and usage volume
Requirements for transparency, complaint handling, and protection of client funds
Strong Customer Authentication (SCA)
The FCA’s rights to surveil, assess, and take action via enforcement against these entities
Electronic Money Regulations 2011 (EMRs 2011)
Regarding the Electronic Money Regulations 2011 (EMRs 2011), they imply a necessity for licensing for those who operate in the electronic money (e-money) provision space. They also apply to acquirers—particularly those operating under hybrid models that combine provision and acquisition facets into one channel.
For example, if your acquiring business also offers e-wallets or prepaid accounts where users can deposit money and use it for other services, you will need to be dual-licensed:
An Authorised Payment Institution (API) under the Payment Services Regulations 2017 (PSRs 2017)
An Authorised Electronic Money Institution (EMI) under the Electronic Money Regulations 2011 (EMRs 2011)
Financial Services (Banking Reform) Act 2013
The Financial Services (Banking Reform) Act 2013 is not directly related to the operations of payment institutions but is part of the broader UK financial services regulatory framework related to financial infrastructure that supports payment systems.
Among other things, this Act established the Payment Systems Regulator (PSR) in 2015 and empowered it to:
Encourage competition in payment systems and development
Ensure fair access to infrastructure offered by larger service providers (including acquirers)
Prevent anti-competitive practices within the payment value chain
For payment acquirers—particularly those requiring direct access to schemes or the settlement infrastructure—this Act formalizes your potential claims to access and operate within the payments network at commercially reasonable rates.
Steps to Become a Licensed Payment Acquirer in the UK
Becoming a licensed payment acquirer in the UK is a structured, regulator-led process. From selecting your regulatory status to onboarding your first merchant, each step must meet the standards set by the Financial Conduct Authority (FCA) and align with broader payment scheme requirements.
This section outlines the six key steps your business must follow to legally launch acquiring services in the UK.
1. Decide on Entity Type: Authorised vs Small Payment Institution
Your first decision is whether you're going to be an:
Authorised Payment Institution (API)
Small Payment Institution (SPI)
APIs are larger enterprises that expect to charge more per transaction, provide a more comprehensive slate of services, or seek longer growth potential. APIs have greater requirements—higher capital thresholds, safeguarding obligations, and more complex governance standards.
SPIs are for those with lower transactional needs (generally under €3 million/month), with easier access and minimum capital outlay and reporting requirements. This limits access to passporting and service potential.
For the majority of acquirers looking to expand, the route is typically through an API choice.
4.2 Prepare Your FCA Application Pack
After determining the suitable entity, the next step is to assemble the complete FCA Application Pack for the FCA's review and approval.
Evidence of your initial capital
Evidence of safeguarding arrangements
AML/CTF, compliance policies, and IT systems
Evidence of your senior managers’ appointment and due diligence (SM&CR forms, etc.)
According to the FCA's guidance, acquiring businesses in regulated industries must create a bespoke application. Failure to provide the requested information will increase processing time.
4.3 Submit Application and Pay Regulatory Fees
Now that your application is ready, submit it via the FCA Connect system. You'll also need to pay the non-refundable regulatory fees, which depend on your acquisition model and transaction volume.
Once submitted, you're in the FCA review queue. APIs typically have a deadline of up to 3 months—although actual timelines often extend to 6–9 months due to FCA feedback timeframes.
4.4 Undergo FCA Assessment and Respond to Queries
The FCA will assess your application, so be ready to respond to follow-up questions in these areas:
Governance and internal controls
Risk management and fraud prevention
Your safeguarding arrangements
Your technology infrastructure and disaster recovery
Maintaining clear communication throughout this stage is essential. The FCA may need clarification, additional documentation, or resolution of concerns before proceeding.
4.5 Receive Authorisation and Begin Onboarding Merchants
Once the FCA is satisfied with all information and requirements, you'll be listed on the FCA Register. Authorisation allows your business to legally conduct regulated acquiring activity in the UK.
However, you still cannot process card payments until the next step: applying to the relevant card schemes.
4.6 Apply for Card Scheme Membership or Partnership
To accept card payments, you must either:
Become a direct member of card schemes (Visa, Mastercard), or
Partner with a principal acquirer already approved by a scheme
With direct membership, you control your acquiring process, but the technical and compliance requirements are substantial. You must complete scheme onboarding and scheme audits, and demonstrate the ability to manage fraud handling, chargebacks, and scheme compliance.
Many new acquirers opt to partner with established processors or scheme members before switching to direct membership as transaction volumes increase.
Core Requirements to Obtain FCA Authorisation
Securing authorisation from the Financial Conduct Authority (FCA) isn’t just about submitting a form — it’s about proving that your business is structured, funded, and governed in a way that meets the regulator’s expectations.
5.1 Minimum Capital Thresholds
The FCA expects all applicants to demonstrate adequate commencement capital appropriate to the payment services being provided.
For acquirers operating as Authorised Payment Institutions (APIs), the minimum capital threshold is:
€125,000 capital requirement for money remittance services (as classified under Annex I of PSRs 2017)
This capital must be liquid, available, and verifiable, not reliant on projected income. Audited confirmations or bank statements must be provided.
5.2 Governance, Senior Management, and SM&CR
The FCA requires acquirers to have a clear governance structure with well-defined responsibilities and a senior leadership team suitable for a regulated financial entity.
You must have:
A Compliance Officer with relevant FCA experience
A Money Laundering Reporting Officer (MLRO) if subject to AML obligations
A senior leadership team with experience in payments, risk, and operations
If your firm falls under the Senior Managers and Certification Regime (SM&CR), you must submit applications for individuals performing a Senior Management Function (SMF). These individuals must be FCA-approved and held personally accountable for regulated activity.
The FCA will assess all key personnel for competence, integrity, and financial soundness.
5.3 Operational and Risk Control Systems
Applicants must demonstrate operational readiness and risk control capabilities appropriate to their acquiring activity.
This includes:
A risk management framework addressing financial risk, operational risk, fraud risk, and reputational risk
Defined internal controls and compliance monitoring processes for transaction processing, compliance breaches, and governance audits
Incident reporting procedures for data breaches, system outages, or security failures
The FCA expects these policies to be implemented, maintained, and periodically reviewed.
5.4 Business Continuity and IT Infrastructure
Acquiring is infrastructure-intensive, and the FCA requires assurance of your systems’ reliability, security, and scalability.
You must provide:
A business continuity plan (BCP) outlining service continuity during outages or disruptions
An IT security policy aligned with ISO 27001 or PCI DSS
A review of core systems architecture, including data flows, third-party dependencies, and backup protocols
If you plan to outsource any core function—such as transaction processing, fraud detection, or data hosting—you must disclose related contracts and demonstrate how you will manage risks in line with outsourcing guidelines in the FCA Handbook (SYSC 8).
Safeguarding and Fund Protection Obligations
Safeguarding is the important compliance requirement expected of UK-authorised payment acquirers to prevent loss of customer funds in case an acquirer goes insolvent or fails to conduct operations as anticipated. For the entities acquiring—those who have the merchant funds directly in hand, receive settlement amounts and take revenue payments—non-compliance with safeguarding requirements results in regulatory enforcement actions and reputational damage.
Segregation vs Insurance-Backed Safeguarding
Safeguarding is the important compliance requirement expected of UK-authorised payment acquirers to prevent loss of customer funds in case an acquirer goes insolvent or fails to conduct operations as anticipated. For the entities acquiring—those who have the merchant funds directly in hand, receive settlement amounts and take revenue payments—non-compliance with safeguarding requirements results in regulatory enforcement actions and reputational damage.
Per the Payment Services Regulations 2017, authorised payment institutions must protect customer funds through one of two safeguarding measures:
Segregation (the most common method): Funds of customers are placed in a separate safeguarding account with an authorised credit institution (normally a UK or EEA bank). This must be separate from the firm’s own operating accounts, meaning that these funds must be clearly distinguished from operational activity and not used for operating income or investment purposes.
Insurance-backed safeguarding: A safeguard insurance policy or bond can be purchased through an insurance company registered with the FCA. This method requires insurance coverage at 100% of safeguarded amounts, subject to eligibility requirements.
Most firms choose the segregation method as it is simpler and aligned with FCA expectations.
Safeguarding Account Setup, Reconciliation, and Audits
If a firm chooses to segregate, there are requirements during the account opening process, the reconciliation process thereafter, and audits:
Opening of safeguarding accounts: These must be named in a way that clearly indicates it is a safeguarding account (e.g., "Client Safeguarding Account - XYZ Ltd"), and the agreement with the banking institution must stipulate restrictions on access/use of such funds.
Daily reconciliation: A firm must reconcile the actual amounts safeguarded to the accounting of what is owed to clients or merchants—at minimum each business day. Any negative balances must be rectified by the end of that business day using the firm’s unsegregated assets.
Annual audit of safeguarding arrangements: An independent audit opinion from the FCA is expected during the firm's annual audit cycle or regulatory compliance review, confirming compliance with safeguarding requirements.
Non-compliance with safeguarding is one of the more common regulatory concerns identified through FCA enforcement and supervisory actions. It remains a focus of both pre-approval assessment and post-approval supervision.
FCA Monitoring and Best Practices
After obtaining approval, the FCA expects firms to demonstrate compliance with safeguarding requirements at any time, including:
Written policies and procedures related to safeguarding
Governance structure and accountability for safeguarding responsibilities
Internal audit/control reviews of safeguarding activities on a regular basis
Incident reporting procedures for any safeguarding breaches or errors
Aside from assessments triggered by firm-specific issues (e.g., complaints), the FCA may request bank confirmations, reconciliation data, and safeguarding figures during thematic assessments or firm reviews. Recently, enforcement actions have increased against firms misallocating funds, delaying reconciliation, or failing to separate firm money from client money.
Best practice tip
Appoint a dedicated safeguarding officer or make safeguarding part of the remit of your compliance team, supported by clear internal reporting lines and automated reconciliation tools.
Anti-Money Laundering (AML) and Financial Crime Compliance
Payment acquirers sit at a critical point in the financial system — facilitating the movement of funds between customers, merchants, and banks. That position comes with a heightened risk of exposure to money laundering, terrorist financing, and fraud. As a result, the UK imposes strict obligations on all regulated acquirers under its anti-financial crime framework.
MLR 2017 Obligations for Acquirers
All FCA-authorised payment institutions must comply with the Money Laundering Regulations 2017 (MLR 2017). Your firm, as an acquirer, will be considered a relevant person and must take the necessary steps to ensure your service is not used to facilitate crime.
Requirements include:
Conducting a business-wide risk assessment to assess exposure to money laundering and terrorist financing
Having formalised AML policies and procedures with board-level approval and periodic updates
Appointing a nominated officer, typically a Money Laundering Reporting Officer (MLRO), for internal and external disclosures
Training relevant staff on red flags and escalation procedures
Documenting and maintaining due diligence records, monitoring activity, and risk assessments
Your AML framework will be reviewed during your application, and the FCA will assess compliance during ongoing supervision.
Customer Due Diligence (CDD), Monitoring, and Screening
For acquirers, the primary AML risk involves onboarding and maintaining relationships with merchant clients. You must conduct Customer Due Diligence (CDD) at the beginning of every merchant relationship and apply Enhanced Due Diligence (EDD) for:
High-risk geographies or high-risk industries (e.g., crypto, gaming)
Politically Exposed Persons (PEPs)
Complex ownership structures
CDD must include:
Identity verification of merchants and beneficial owners
Understanding the business’s purpose, payment flow, and transaction behaviour
Sanctions screening and PEP list screening, including checks against HM Treasury and OFAC lists
You must also conduct ongoing monitoring, assessing merchant transaction behaviour in real-time or near-real-time using automated rules and behavioural flags to identify suspicious activity.
Suspicious Activity Reports (SARs) and Reporting to the NCA
If ongoing monitoring raises unresolved concerns, you may be required to submit a Suspicious Activity Report (SAR) to the National Crime Agency (NCA).
SARs are required when there is suspicion or awareness that a transaction involves:
Criminal property
Proceeds of crime
Terrorist financing
Your firm must have:
An internal escalation procedure (typically to the MLRO)
SAR decision records indicating whether the firm accepted or rejected the report
Capability to submit via the NCA online portal
The NCA may issue a defence against money laundering (DAML), which means you must halt the transaction during the moratorium period until further instruction is given.
PCI DSS, SCA, and Technical Compliance Standards
In addition to financial and operational compliance, payment acquirers in the UK must meet stringent technical, security, and fraud prevention standards. These are essential not only for regulatory approval but also for maintaining card scheme membership and customer trust.
PCI DSS Scope for Acquirers
PCI DSS (Payment Card Industry Data Security Standard) is a global standard developed by card schemes (Visa, Mastercard, etc.) and regulators to protect cardholder data. Acquirers must maintain PCI compliance.
Acquirers are within PCI scope if any systems interface with, process, or store cardholder data or sensitive authentication data.
This includes:
Acquiring platforms and payment gateways
Payment routing and tokenisation systems
Any merchant-facing services operated from your infrastructure
Affected entities must:
Align with the PCI scope of the acquirer
Complete either a Self-Assessment Questionnaire (SAQ) or undergo a QSA-led audit (Qualified Security Assessor)
Implement data encryption, access controls, and secure logging within the PCI scope
Maintain a tested incident response plan.
Acquirers and card schemes must demonstrate compliance annually. If payment processors are not PCI-certified, they risk fines, scheme non-compliance sanctions, or loss of ability to support credit card processing.
Strong Customer Authentication (SCA) and RTS Compliance
Strong Customer Authentication (SCA) is required under the UK implementation of the EU Regulatory Technical Standards (RTS) on SCA and Secure Communication, as mandated by PSD2.
SCA enforces two-factor authentication for most card-not-present transactions. While acquirers don’t execute authentication, they must:
Support SCA-compliant message flows in coordination with merchants and issuers.
Implement and maintain 3D Secure (3DS) and associated protocol upgrades
Educate merchants on proper exemption logic usage (e.g., low-risk exemptions)
Non-compliance with SCA can result in declined transactions and chargebacks that cannot be contested. Acquirers are expected to proactively monitor authentication performance and act on fraud detection and red flags.
Fraud Detection and Incident Reporting
Fraud detection and effective response are core compliance obligations for payment acquirers.
Deploy transaction monitoring systems using rule-based or machine learning-based fraud prevention, tailored to merchant behaviour.
Implement chargeback management and structured dispute-handling processes.
If a security incident occurs (e.g., data breach, or significant fraud), you are required to notify the FCA without undue delay. Notification obligations are detailed in SUP 15.3 of the FCA Handbook. Incidents that may trigger reporting include:
Material customer impact
Significant data loss
Major operational disruptions
Additionally, card schemes may require separate notifications and initiate forensic investigations, especially in cases involving compromised PAN or CVV data.
Post-Authorisation FCA Compliance Requirements
Once authorised by the Financial Conduct Authority (FCA), payment acquirers must comply with ongoing post-authorisation compliance obligations. These standards are mandatory—non-compliance can risk your regulated status, endanger client funds, or result in conduct breaches under UK regulations.
All regulated payment firms must submit regulatory returns through the RegData platform on a scheduled basis. Acquirers are primarily responsible for submitting:
REP017 report – includes payment services data such as transaction volumes, fraud statistics, and customer complaints
REP018 report – covers operational and security risks, including resilience measures
REP017 relates to market activity and service performance, while REP018 addresses non-fraud-related operational incidents and evaluates your firm’s resilience. These reports are used by the FCA to monitor your risk profile. Submission deadlines vary based on firm size but must be timely, accurate, and consistent with previous filings to avoid scrutiny for misreporting or delays.
Under SUP 15 of the FCA Handbook, authorised firms must notify the FCA of material changes or incidents, including:
Changes to control, directors, senior management, or regulated activities
Data breaches, major fraud incidents, or operational suspensions
Such events must be reported within the required notification window—typically one business day. Notifications must be submitted through official channels, clearly and promptly.
Acquirers must also comply with governance expectations set out in the Senior Managers and Certification Regime (SM&CR). This includes ensuring that senior managers and certified staff demonstrate integrity, uphold effective risk management, and promote fair customer outcomes.
Additionally, firms are subject to extensive recordkeeping practices, including:
Transaction logs
Safeguarding reconciliations
Complaints records
Internal audit trails
These records must be retained for a minimum of five years and be available for FCA review at any time.
Finally, all FCA-regulated acquirers are responsible for paying FCA annual fees, determined by firm size and regulatory permissions. These must be paid on time to avoid penalties or enforcement action.
Card Scheme Membership and Acquirer Licences
Authorisation from the FCA allows you to operate as a payment acquirer under UK law — but it does not, by itself, give you access to the card networks. To process card transactions for merchants, you must either become a licensed member of card schemes like Visa and Mastercard or work with a scheme-approved partner.
Visa/Mastercard Scheme Onboarding Process
There is a scheme-specific onboarding and certification testing process. This is a secondary, intensive approval that occurs concurrently with your FCA registration, and it is equally rigorously reviewed. During Visa scheme onboarding and Mastercard scheme onboarding, the card schemes will assess your:
Legal status and FCA registration
Financial strength and capital reserves
Risk management systems and fraud management systems
Technical readiness, including PCI DSS compliance
Chargeback handling procedures and internal governance
In addition, scheme network integration is required, including transaction testing and approval, and may involve letters of support from bank sponsorship or processing partners. Scheme onboarding can take several months and should be factored into your launch timeline.
Direct vs Sponsored Membership Models
New and scaling acquirers must decide between direct membership and sponsored membership.
With direct membership, your firm becomes a scheme member and takes full responsibility for scheme compliance, settlement, and risk management. This model requires fulfilling a wide range of technical, financial, and operational controls, including the provision of a scheme guarantee, access to clearing funds, and compliance with all scheme rules.
Sponsored membership allows firms to access schemes via a principal member, bank sponsor, or acquirer-processor. This option reduces operational complexity and accelerates time to market, as the sponsor generally manages scheme communications, settlement, and compliance infrastructure. However, it limits your control over internal governance, pricing, operations, and branding.
Regardless of the model, firms must maintain a defined internal governance framework and robust risk controls.
Scheme Compliance Obligations and Audits
Joining a scheme through Visa or Mastercard brings ongoing scheme compliance requirements and regular scheme audits, including:
Ongoing PCI DSS compliance
Fraud data reporting, chargeback data reporting, and performance data reporting
Participation in scheme-led reviews or audits
Addressing compliance alerts for issues such as fraud thresholds or late settlements
Card schemes take swift action against non-compliant acquirers—ranging from fines to membership termination. To mitigate risk, acquirers must stay aligned with scheme updates and conduct regular internal reviews in collaboration with compliance and revenue operations teams.
How DECTA Supports Licensed Acquirers with Turnkey Acquirer Processing
DECTA offers a comprehensive turnkey acquirer processing solution through a unified acquirer processing platform that delivers tailored services to meet the needs of banks and financial institutions. These solutions simplify acquiring from both a regulatory compliance, payment data security, and functional standpoint.
What DECTA Offers for Acquirer Processing:
Merchant Onboarding and Management: Automated MID (Merchant Identification Number) and TID (Terminal Identification Number) management are available 24/7. DECTA's legal entity handling, rate plans, and visibility into merchant and terminal IDs reduce administrative burdens for faster merchant onboarding.
Transaction Routing and Processing: Supports omnichannel processing. DECTA consolidates sales channels into a single system that enables seamless POS (Point of Sale) integration and mobile payments.
3D Secure Payment Authentication: DECTA enables support for the latest 3D Secure (3DS v2.2) standards and full PSD2 compliance, including Strong Customer Authentication (SCA). This helps reduce fraud risk and increase payment acceptance rates.
Tokenized Payments: Accept tokenized payments through eWallet integration with Apple Pay, Google Pay, and Samsung Pay. Tokenization provides fast and secure transactions both in-store and online.
Direct Scheme Connectivity and PCI-Compliant Stack: DECTA provides direct scheme connectivity, including both Mastercard connectivity and Visa connectivity, supported by a PCI DSS Level 1 certification infrastructure for maximum payment data security.
DECTA’s acquirer processing platform provides licensed acquirers with a secure, scalable infrastructure trusted by merchants for reliable transaction routing and varied payment processing capabilities.