April 1, 2026

The Payments Newsletter including Digital Assets & Blockchain, March 2026

LinkedIn Facebook X Send Embed

[co-author: Mengze Han]

Key developments of interest over the last month include: the UK FCA publishing its annual Regulatory Priorities reports for payments, retail banking and consumer finance; the European Central Bank launching a call for expression of interest for participation in the digital euro pilot; and, in the United States, Delaware's governor announcing the publication of two new bills which, among other things, would formally define digital assets under Delaware law and create a licensing regime for stablecoin issuers and digital asset firms.

In this Newsletter:

• Regulatory Developments: Payments
• Regulatory Developments: Digital Assets
• Market Developments
• Surveys and Reports For previous editions of the Payments Newsletters, please visit our Financial Services practice page.

Global: FSB launches new implementation phase to advance cross border payments through public-private collaboration

On 12 March 2026, the Financial Stability Board (FSB) announced the start of a new implementation phase under the G20 Roadmap for Enhancing Cross border Payments, following discussions at the FSB Cross border Payments Summit in London. The summit brought together senior policymakers and industry leaders to review progress towards making cross border payments faster, cheaper, more transparent, and more accessible. In his opening speech, FSB Chair Andrew Bailey emphasised that strong commitment and coordinated action from both the public and private sectors are essential to delivering the Roadmap’s objectives.

The next phase will focus on two priorities: encouraging public authorities to develop action plans to drive implementation, and strengthening public private collaboration, with industry expected to play a decisive role in delivering tangible benefits for end users. As the 2027 target date approaches, the FSB will ask its members to identify practical priorities and actions to enhance payment systems at both jurisdictional and broader regional levels. The Institute of International Finance and Swift also set out initiatives to support progress towards the Roadmap’s goals.

United Kingdom: PSR response to Treasury Committee questions on payments regulation

On 10 March 2026, the House of Commons Treasury Committee published a letter (dated 27 February 2026) from David Geale, Managing Director of the Payment Systems Regulator (PSR) and Executive Director for Payments and Digital Finance at the FCA, providing information following an oral evidence session on 4 February 2026.

Key areas addressed by Mr Geale include:

• PSR powers and legislative framework: The PSR is not seeking broad new powers as part of its consolidation with the FCA but does see targeted opportunities where legislative change could improve the framework such as simplifying access arrangements and enhancing appeals and enforcement mechanisms for information gathering notices. These changes would support a more coherent and effective regulatory system while preserving the PSR’s distinct remit. It continues to engage with HM Treasury on how these issues may be addressed through the ongoing legislative process. On the FCA’s and the PSR’s concurrent competition regulatory remits, the PSR is also engaging with the Department for Business and Trade (DBT) on its proposals to improve coordination and clarify responsibility between concurrent regulators, including around supervision of existing remedies.
• Supervisory approach: The PSR is considering how best to refine and communicate its supervisory approach in light of its planned consolidation into the FCA and will conclude its approach once legislation is finalised.
• Scam related takedown requests: Regarding the regulators’ approach to holding data on the time taken for technology firms to respond to requests to remove scams on social media, the FCA does not routinely track the time technology firms take to respond to its removal requests, as it believes the firms are best placed to monitor these response times and update the FCA and Parliament. However, it does hold data related to a subset of removal requests submitted through a third-party firm that the FCA uses to help with its takedown requests. Further information is included in the letter.

United Kingdom: Government publishes Fraud Strategy 2026-2029

On 9 March 2026, the Home Office published the government’s Fraud Strategy 2026-2029: Disrupting crime, supporting economic resilience and delivering justice.

The new Strategy sets out a system-wide approach to combating fraud across online platforms, telecommunications infrastructure, and financial services. It emphasises disrupting fraud at source, strengthening cross-sector intelligence sharing, and improving accountability for sectors that scammers exploit.

Points of interest from the Strategy include:

• Strong Customer Authentication (SCA): The SCA technical standards will be repealed and replaced with an outcomes-based approach from the FCA. The aim is to support the adoption of new and continuously improvable authentication methods, while applying risk-based measures for lower-risk transactions.
• Passkeys: The National Cyber Security Centre (NCSC) will continue to work with standards bodies, technology providers, and industry partners to accelerate the adoption of passkeys. Financial institutions will be encouraged to use NCSC guidance on strong authentication and certified Digital Verification Services.
• Call for evidence on economic crime information sharing: Assessing the scale, drivers and enablers of unauthorised fraud, the call for evidence will generate an improved evidence base and potential next steps by the end of 2026 under the UK Digital Identity and Attributes Trust Framework.
• APP fraud / money mule activity: The FCA will consider examples of practices for preventing APP fraud and money mule activity and will share its recommendations with the financial services sector.
• Investing £31 million in the Online Crime Centre: Opening in April 2026, this will be a centralised hub for intelligence to tackle online fraud. It is a public/private partnership which brings together law enforcement, the intelligence community and the financial, technology and telecommunications sectors.
• New cryptoasset legislation: Cryptoasset firms will be brought under the full financial services regulatory framework by October 2027. This includes requirements for FCA authorisation and compliance with standards similar to traditional financial institutions. For further analysis on the new strategy, see this Our Thinking article.

United Kingdom/European Union: Payments Association publishes report on role of digital platforms in APP fraud prevention and the case for shared liability

On 25 March 2026, the Payments Association published a report entitled ‘ The new origin of APP fraud: Evidence of digital platforms’ role and the case for shared liability ’.

The report examines how fraud develops in practice and explores whether current accountability frameworks reflect that reality, including looking at emerging UK, EU and international regulatory developments.

The report concludes that, as APP fraud is not just a payments issue and most scams begin on digital platforms, marketplaces and messaging services, existing frameworks need to be adapted to reflect this. It calls on the UK Government, EU policymakers, and regulators to introduce enforceable measures on scam advertising and platform accountability, including:

• coordinated regulatory action on advertiser verification;
• faster removal of fraudulent content;
• structured intelligence sharing; and
• clearer accountability and financial repercussions when platforms repeatedly fail to prevent scam exposure at source. According to the report, if fraud is to be reduced at scale it is essential that where platforms operate systems that enable large-scale scam exposure, they should also be expected to play a proportionate role in preventing it.

United Kingdom: FCA, PRA and BoE publish policy statements on operational incident and third party reporting

Following consultations in December 2024, on 18 March 2026 the FCA, PRA and Bank of England (BoE) published policy statements and other related materials on operational incident and third-party reporting. In outline:

• FCA policy statement (PS26/2): The FCA sets out the final text of amendments to its Handbook to reflect the new reporting regime. These are set out primarily in new SUP 15.18 (Notification of operational incident) and SUP 15.19 (Notification of material third party arrangements). The FCA has also published finalised guidance on operational incident reporting (FG26/3) and material third party reporting (FG26/4), and amendments to its Payment Services and E-Money Approach Documen t that reflect the new operational incident reporting regime.
• PRA policy statement (PS7/26): The PRA sets out the final text of amendments to its Rulebook to reflect the new reporting regime. These are set out primarily in amendments to the Notifications Part and the Regulatory Reporting Part. The PRA has also published a new supervisory statement (SS1/26): Operational resilience: incident reporting and revisions to its supervisory statement on outsourcing and third-party risk management (SS2/21).
• BoE policy statement and consultation paper: The BoE sets out the final text of amendments to its rules for financial market infrastructures (FMIs) relating to the new reporting regime, referred to by the BoE as "operational incident and outsourcing and third-party reporting" (IOREP). The BoE has also published: a new supervisory statement on operational incident reporting for FMIs; an updated version of its supervisory statement on outsourcing and third-party risk management for central counterparties (CCPs); an updated version of its supervisory statement on outsourcing and third-party risk management for central securities depositories (CSDs); and an updated version of its supervisory statement on outsourcing and third-party risk management for recognised payment system operators and specified service providers. The BoE is also consulting on proposals to revoke Rule 4 of the Recognised Clearing House Rules Instrument 2018 for CCPs, on the basis that it duplicates the effect of the IOREP incident reporting rules. The deadline for responses is 18 June 2026. The new rules and guidance will come into force on 18 March 2027. In its policy statement, the FCA states that, before this date, it will engage with firms to support them in their work to adapting to the new regime. It also intends to review its policy on operational incident and third-party reporting two years after implementation to assess if it meets its needs and those of firms.

United Kingdom: CMA issues research and guidance on using AI agents with consumers

On 9 March 2026, the Competition and Markets Authority (CMA) published guidance for businesses on how to use agentic AI to engage with customers, while still complying with consumer law. The CMA also published research reviewing current and anticipated use of agentic AI and its risks and benefits.

The guidance makes clear that when dealing with consumers, the same rules apply whether using AI or human agents and reminds businesses that customers must be treated fairly. Businesses are responsible for what an AI agent does in the same way as for an employee’s actions.

The guidance recommends that businesses:

• Inform customers if using AI agents. Consumer law requires that consumers are not misled and are provided with information they need to make informed decisions. However, businesses should not overstate the role of AI involved in providing a service, or what it can or cannot do.
• Train AI agents to comply with consumer law. Businesses need to ensure AI agents respect customers’ statutory rights and relevant contractual terms, obtain any necessary consents and avoid any misleading interactions. Ensuring agents have appropriate data and are fully tested is crucial.
• Monitor how AI agents are performing. Appropriate processes should be in place to monitor AI agents, including a human being involved at some point to check the AI-decision making and AI-generated results.
• Refine the AI agent quickly if a problem arises. It may be necessary to refine prompts or workflows if a problem is identified. This is especially important where an AI agent interacts with large numbers of customers, particularly if they are vulnerable. Alongside the guidance, the CMA has published research which states that currently businesses are using agentic AI in bounded and controlled ways, including customer operations and service, commerce and sales workflows, software and IT operations, and internal business process automation. Potential future uses include forms of agentic commerce, where agents monitor prices, availability or contract terms over time and initiate defined actions. The research identifies applicable law, different risk areas and mitigations and provides a worked example of these in the context of an agentic personal shopping and finance agent.

United Kingdom: FCA publishes annual Regulatory Priorities reports for payments, retail banking and consumer finance

On 25 March 2026, the FCA published its first annual Regulatory Priorities: Payments report.

The FCA’s 4 main areas of focus for 2026 are:

• Preparing for the future to support effective competition, innovation and growth: The emphasis here is on some key initiatives under the National Payments Vision and related Payments Forward Plan, namely supporting the expansion of Open Banking, modernising payments regulation – which will include considering whether change or development of regulation is needed to support agentic AI payments - and exploring stablecoins for payments.
• Ensuring firms implement the Consumer Duty effectively: The FCA plans to do work to reinforce its expectations on the Duty with firms, with focus areas to include international payment pricing transparency and firms’ treatment of vulnerable consumers.
• Protecting financial system integrity: While the FCA has been encouraged by some firms significantly enhancing their governance, oversight, and systems and controls, weaknesses in this area still pose risks to market integrity. Actions it plans to take this year include continuing to assess firms’ governance, oversight, and systems and controls relating to financial crime and operational resilience, taking action against firms that consistently fail to meet standards. It also refers to the enhancement of its operational resilience framework through its recently published policy statement – along with those of the Bank of England and the PRA - on incident and third-party reporting rules (see the separate item on this).
• Keeping customers’ money safe: Some firms don’t have robust safeguarding practices and haven’t fully developed their risk management frameworks and wind-down plans. The FCA intends to continue assessing firms’ governance, oversight, and systems and controls relating to financial resilience and safeguarding and to take action where necessary. It is also going to focus on implementation of its Safeguarding Supplementary Regime (coming into force on 7 May 2026), and consider the outcomes of safeguarding audits and address issues with firms. The FCA warns that as it has strengthened standards in this area, there may be an increase in ‘adverse’ audit opinions in the short term. Other focus areas for 2026 are: Open Banking and Open Finance; stablecoins; international cooperation; and artificial intelligence.

Firms are directed to the recently published Payments Forward Plan (see our February 2026 Newsletter) for details of upcoming payments sector initiatives.

Other recent FCA sector reports include:

• Regulatory Priorities: Retail Banking repor t (12 March): In relation to payments, the FCA’s priorities for 2026 in this sector include access to cash and essential banking services, with an expectation that firms’ digital transformations must avoid causing foreseeable harm to retail customers, particularly those who are less digitally capable. Firms should ensure that any alternative services proposed are accessible to customers before branch closures occur. The FCA will closely monitor firms’ performance on branch closures and the Consumer Duty, intervening where necessary. The FCA also mentions innovation in retail banking as a focus area, including developments relating to stablecoins and tokenised deposits.
• Regulatory Priorities: Consumer Finance report (17 March): In relation to payments, the FCA identified Deferred Payment Credit (DPC) as a key area of focus in the consumer finance sector, with DPC lenders expected to prepare for the new Buy Now, Pay Later (BNPL) regime coming into force in July 2026.

United Kingdom: New risk-based exemption for contactless payments in force and updated FCA Approach Document published

On 19 March 2026, amendments to Article 11 of the Strong Customer Authentication (SCA) Regulatory Technical Standards (RTS) to enable payer payment service providers (PSPs) to opt not to apply SCA at the point of sale for a contactless payment that has been reasonably identified as posing a low level of risk through their transaction monitoring mechanisms came into force (see the relevant FCA Instrument here).

Also on 19 March, the FCA published a revised version 7 of its Approach Document with changes to Chapter 20 (Authentication) to provide that additional factors, such as normal spending or behavioural pattern of the payer or location of the payer, can be considered to establish whether the transaction is low risk. PSPs may also look to the value of the individual contactless electronic payment transaction in question as well as the cumulative value of previous contactless electronic payment transactions and/or the number of consecutive contactless electronic payment transactions made since the last application of SCA. The changes that have been made to the Approach Document are shown in the Appendix to FCA Handbook Notice No.136 (December 2025).

Going forward, banks and PSPs with strong fraud controls will be able to set their own limit for contactless payments, allowing them to better respond to changing consumer demands, inflation and new technology. They are also being encouraged to let customers set their own limit, or turn contactless off altogether, as many high street banks already do.

United Kingdom: FCA publishes findings from review of firms’ approaches to consumer understanding outcome

On 13 March 2026, the FCA published a webpage setting out the findings of a review into firms’ approaches to delivering the consumer understanding outcome under the Consumer Duty, alongside examples of good practice and areas for improvement. The FCA focused on five areas relevant to how firms support customer understanding: management information (MI) and testing; innovation and communication design; vulnerability and accessibility; financial promotions; and governance and oversight. The examples provided are relevant to all firms, including smaller firms, that offer products or services to retail customers. The FCA expects firms to use the findings to assess their own approaches and identify where improvements may be required to meet their obligations under the Consumer Duty.

United Kingdom: FCA publishes direction on application period for cyptoasset regulated activity permission

On 27 February 2026, the FCA published a direction (dated February 2026) under regulation 52 of the Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2026 (SI 2026/102) specifying the application window for firms seeking permission to carry on new cryptoasset regulated activities. The application gateway will open at 9.00 am on 30 September 2026 and close at 11.59 pm on 28 February 2027. The direction confirms the application period previously announced in January 2026 and may be extended by the FCA.

United Kingdom: FCA publishes webpage for cryptoasset firms on use of section 21 approvers for financial promotions

On 27 February 2026, the FCA published a new webpage providing guidance for cryptoasset firms that are neither authorised under the Financial Services and Markets Act 2000 (FSMA) nor registered with the FCA under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (SI 2017/692), and which may use authorised firms as “section 21 approvers” to approve their cryptoasset financial promotions for communication to UK consumers.

The FCA explains how the use of section 21 approvers will operate in light of the forthcoming cryptoassets regulatory regime, distinguishing between different categories of firms:

• Cryptoasset firms that apply for authorisation during the application period may continue to rely on their existing section 21 approver until their application is determined.
• Cryptoasset firms that do not apply during the application period (between 30 September 2026 and 28 February 2027) may continue using their section 21 approver until the new regime commences on 25 October 2027. At that point, if the firm’s application has not been determined, it will enter the transitional provision and will only be permitted to communicate promotions relating to pre existing contracts, which will not require a section 21 approver.
• Cryptoasset firms that do not apply for authorisation (or variation) before the new regime commences must run off their UK cryptoasset business before the new regime begins or risk breaching restrictions under FSMA.

United Kingdom: FCA publishes quarterly consultation no. 51 on proposed changes to the Handbook

On 6 March 2026, the FCA published its quarterly consultation paper no.51 (CP26/8), inviting comments on proposed miscellaneous changes to the FCA Handbook.

The proposals include amendments to the Client Assets Sourcebook (CASS) to clarify how the client money rules apply to cryptoassets, including treating safeguarded cryptoasset related funds as client money, excluding stablecoin backing funds, extending segregation requirements, and removing certain exemptions such as delivery versus payment (DvP) and professional client opt outs.

The deadline for response is 13 April 2026.

United Kingdom: Bank of England indicates flexibility on proposed holding caps for systemic stablecoins and provides update on timing for publication of draft rules

On 11 March 2026, the Bank of England (BoE) indicated in oral evidence to the House of Lords Financial Services Regulation Committee that it is open to revisiting its proposed limits on holdings of systemically important stablecoins following industry criticism. Deputy Governor Sarah Breeden stated that the BoE is “genuinely open” to alternative approaches to managing financial stability risks, other than holding limits, particularly the risk of a rapid migration of deposits from commercial banks into stablecoins.

The proposed holding limits, set out in a November 2025 consultation paper, would cap individual holdings at £20,000 and business holdings at £10 million on a temporary basis, with the aim of supporting an orderly transition as stablecoin use expands. Industry participants have argued that the caps may be difficult to enforce and risk stifling innovation, prompting the BoE to review feedback.

The BoE also indicated that it expects to publish draft rules for the regulatory regime governing sterling denominated systemic stablecoins in June 2026.

For more on the BoE’s November 2025 consultation, take a look at this Our Thinking article.

United States: Delaware publishes bills to modernise banking framework and set out new rules for digital assets and stablecoins

On 23 March 2026, Delaware’s governor announced the publication of two new bills:

• The Delaware Banking Modernization Act (S.B.16) would, among other things, formally define digital assets under Delaware law; and
• The Delaware Payment Stablecoin Act (S.B.19) would, among other things, create a licensing regime for stablecoin issuers and digital asset firms. According to press reports, the bills have been assigned to the Delaware Senate Banking, Business, Insurance & Technology Committee for consideration and, if released, they will be presented to the full State Senate before going to the State House of Representatives.

European Union: ECB launches call for expression of interest for participation in the digital euro pilot

On 5 March 2026, the European Central Bank (ECB) launched a call for expression of interest from payment service providers (PSPs) to participate in the digital euro pilot.

The ECB aims to be technically ready for a potential first issuance of the digital euro in 2029, subject to the adoption of the digital euro Regulation in 2026. A decision on whether to issue a digital euro will only be taken once the Regulation is adopted, with the Eurosystem’s preparatory work remaining flexible to align with the legislative process.

To support this preparation, the ECB plans to run a 12 month pilot starting in the second half of 2027. The pilot will test a beta version of the digital euro to validate infrastructure in real-life situations, such as making in-shop or person-to-person payments. It will check whether the system is robust, user-friendly and scalable. Participants will include selected PSPs licensed in the euro area, merchants and Eurosystem staff.

The ECB has published supporting documentation setting out the pilot’s scope, PSP selection criteria, application questionnaire, timeline and anticipated future documentation, including a pilot PSP participation agreement. Interested PSPs must submit the completed questionnaire by 14 May 2026 and may apply for a distributing role, an acquiring role, or both. The ECB also held an online information session on 20 March 2026 to support PSPs in preparing their applications.

European Union: Eurosystem publishes Appia roadmap for Europe’s tokenised financial markets

On 11 March 2026, the Eurosystem published the Appia roadmap, which forms the cornerstone of its strategy to support the provision of central bank money in innovative, tokenised wholesale financial markets using technologies such as distributed ledger technology (DLT).

Through Appia, the Eurosystem aims to preserve the effectiveness of monetary policy, financial stability and the smooth functioning of payment systems by maintaining central bank money as the anchor of a two tier monetary system, while fostering a more integrated, competitive and innovative payments and securities ecosystem. The initiative also seeks to strengthen strategic autonomy, enhance resilience and safeguard the euro’s role as an international currency.

In cooperation with public and market stakeholders, the Eurosystem plans to deliver a blueprint under Appia for a long term solution by 2028.

Japan: Bank of Japan to test blockchain based settlement for reserves

On 3 March 2026, it was reported that the Bank of Japan (BOJ) had announced plans to conduct experiments using blockchain technology to settle reserves held by financial institutions at the central bank. Governor Kazuo Ueda said the tests would form part of the BOJ’s “sandbox” project to enable the use of central bank money for a range of blockchain based settlements.

In parallel, the BOJ has joined an international experiment to develop a mechanism allowing central banks to issue money as tokenised deposits on blockchains, which could streamline cross border payments if successful.

Turkey: Government proposes crypto income tax and transaction tax

On 2 March 2026, it was reported that Turkey’s ruling party had submitted a draft bill to parliament proposing a new tax framework for cryptoassets. The proposal includes a 10% withholding tax on income and gains from cryptoasset transactions on regulated platforms, as well as a 0.03% transaction tax on sale and transfer transactions conducted by cryptoasset service providers. The bill forms part of the government’s efforts to tighten oversight of the sector, as crypto use in Turkey has grown rapidly amid high inflation and currency depreciation.

Australia: Senate committee endorses digital assets regulatory framework

On 16 March 2026, it was reported that Australia’s Senate Economics Legislation Committee had supported the government’s proposed Corporations Amendment (Digital Assets Framework) Bill 2025, recommending legislation to bring cryptoasset platforms and custody services within the existing financial services regime. The new framework would require digital asset platforms and tokenised custody providers that hold client assets to obtain an Australian Financial Services Licence and comply with asset safeguarding and disclosure requirements. The committee said the proposals would modernise oversight of the sector and address regulatory gaps as crypto activity continues to expand. As Australia’s first comprehensive regulatory framework for digital asset platform, the bill will now proceed through the next stages of the parliamentary process.

Global: FATF publishes report on stablecoins and unhosted wallets

On 3 March 2026, the Financial Action Task Force (FATF) published a targeted report for jurisdictions and the private sector on good practices to mitigate the risks arising from the misuse of stablecoins.

The report highlights that stablecoins have featured prominently in money laundering, terrorist financing and proliferation financing schemes, particularly through peer to peer transactions conducted via unhosted wallets.

FATF recommends that jurisdictions recognise the specific risks associated with stablecoins, taking into account the features that distinguish them from other virtual assets. For example, it emphasises the need to ensure that all relevant participants in stablecoin arrangements are subject to clear anti money laundering and counter terrorist financing obligations.

Good practices for mitigating risks include:

• Requiring stablecoin issuers to adopt risk‑based technical and governance controls, such as the ability to freeze, burn or withdraw stablecoins in the secondary market, and to conduct customer due diligence at redemption;
• Developing strong technical expertise within supervisory and law enforcement authorities, including in relation to smart contract functionalities, blockchain analytics tools, and risks arising from peer‑to‑peer transactions via unhosted wallets;
• Ensuring that competent authorities have the tools and legal frameworks necessary for rapid domestic and international cooperation, for example by putting in place established channels, memoranda of understanding and mechanisms enabling swift information exchange; and
• Establishing public private partnerships to strengthen cooperation on typologies, risk indicators and emerging threats, as well as more tactical partnerships to support investigations.

Global: FATF publishes report on mitigating risks of offshore virtual asset service providers

On 11 March 2026, the Financial Action Task Force (FATF) published a report on understanding and mitigating the risks associated with offshore virtual asset service providers (oVASPs).

oVASPs are virtual asset service providers (VASPs) established under the laws of one jurisdiction, with or without a physical presence, that offer services to clients domiciled or residing outside their jurisdiction of incorporation or physical location. The report focuses on circumstances in which an oVASP provides services without being licensed or registered in a relevant jurisdiction, increasing risks of money laundering and terrorist financing. The report examines how oVASPs organise their activities to avoid or evade regulatory obligations and exploit supervisory gaps.

To mitigate these risks, it identifies the following measures:

• Detecting, registering or licensing oVASPs using an activity based approach;
• Enforcing sanctions for breaches of anti money laundering (AML) and counter terrorist financing (CTF) requirements; and
• Strengthening coordination through inter agency task forces and public private partnerships. Section 4 of the report addresses the role of financial institutions. FATF recommends that financial institutions assess their exposure to unlicensed or unregistered oVASPs, apply clear and consistent AML and CTF controls, and ensure that no group entity operates as an oVASP outside regulatory oversight.

Europe: Santander and Mastercard deliver Europe's first live end-to-end payment executed by an AI agent

On 2 March 2026, Banco Santander and Mastercard announced that they had successfully completed the first live end-end-end payment executed by an AI agent in Europe, marking a milestone in agentic payments within a regulated banking framework. The transaction was conducted in a controlled environment using Mastercard Agent Pay and processed through Santander's live payments infrastructure to test the end-to-end operational and control framework under real conditions. The solution allows AI agents to initiate and execute payments on behalf of customers within predefined limits and permissions, while maintaining established security, privacy and consumer protection standards. Santander will carry out extended testing and scaling of the AI-driven transaction model.

Latin America: Santander and Visa complete Latin America's first end-to-end payments powered by AI agents

On 12 March 2026, Banco Santander and Visa announced that they had completed the first controlled pilot of agentic commerce transactions across five Latin American markets: Argentina, Brazil, Chile, Mexico and Uruguay. The pilot, powered by Visa Intelligent Commerce, tested AI‑assisted transactions within existing regulated payment frameworks. AI agents successfully initiated purchases on behalf of consumers within defined consent and control parameters, validating key elements such as consent capture, secure data handling and interoperability across payment networks. This collaboration supports the advancement of practical agentic commerce use cases and the establishment of a framework for responsible and scalable adoption across the region.

Malaysia: Mastercard completes Malaysia's first live agentic transaction with CIMB and RHB

On 4 March 2026, Mastercard announced the completion of the first authenticated agentic transactions in Malaysia, in collaboration with CIMB and RHB. Conducted using Mastercard Agent Pay, the pilot tested AI‑initiated payments within a controlled environment, ensuring security, transparency and full consumer control. In the pilot, an AI agent booked a transportation service from Kuala Lumpur International Airport to KL Sentral, using tokenised credentials authenticated with Mastercard Payment Passkeys to support strong customer verification and data protection. The pilot demonstrated the technical and operational feasibility of agentic transactions in Malaysia. Mastercard will work closely with banks and partners to roll out commercial deployment in phases, including educating consumers on agentic commerce.

Global: Mastercard introduces new Crypto Partner Programme

On 11 March 2026, Mastercard announced the launch of a new Crypto Partner Programme, a global initiative bringing together more than 100 crypto‑native companies, payments providers and financial institutions. The programme is designed to support collaboration, the sharing of expertise, and the development of scalable, compliant on‑chain payment solutions. Participants will engage with Mastercard on the design of future products that combine digital asset capabilities with established payment infrastructure. The initiative builds on Mastercard's longstanding partnership approach to digital assets.

Global: Mirakl and J.P. Morgan Payments partner to support agentic commerce at enterprise scale

On 7 March 2026, Mirakl and J.P. Morgan Payments announced a global strategic agreement to enable agentic commerce at enterprise scale. Mirakl Nexus provides the commerce layer, enabling AI‑driven product discovery, transactions, and aftersales management. J.P. Morgan Payments delivers secure payment processing, tokenisation, and fraud and risk management to support AI‑driven transactions at scale. Together, the solution aims to deliver an optimal end‑to‑end agentic commerce experience with seamless merchant integration and global scale and reliability. Mirakl and J.P. Morgan Payments are currently working with select retailers and merchants in a closed beta programme, with broader availability planned for 2026.

United States: X Money to enter early public access in April 2026

On 10 March 2026, it was reported that Elon Musk has announced that X Money, the digital payments service of the social media platform X, will enter early public access in April 2026. The initiative aims to leverage X's large user base and the growing demand for in‑app financial transactions to create new revenue streams for the platform. X partnered with Visa last year to help offer direct payment services to users on X. This move aligns with Musk's broader plan to expand the platform into an “everything app” by integrating payments alongside other features, including streaming and messaging.

United States: Klarna partners with Stripe to expand agentic commerce payments

On 3 March 2026, Klarna announced that its flexible payment options will be supported in agentic AI shopping experiences through Stripe's Shared Payment Tokens, a payment tool built specifically for agentic commerce that enables AI agents to initiate purchases using consumers' preferred payment methods without accessing underlying payment details. The integration will make Klarna's interest‑free payments available in AI‑powered checkouts for U.S. merchants already using Klarna via Stripe, with no additional setup required. Klarna aims to ensure that buy now, pay later options remain available in AI‑driven checkout flows, addressing a growing gap in agentic commerce.

Global: Visa and Bridge expand collaboration on global stablecoin‑linked card issuance

On 3 March 2026, Visa and Bridge announced an expansion of their collaboration to issue stablecoin‑linked Visa cards to over 100 countries. Bridge, a stablecoin infrastructure platform and Stripe company, allows businesses to offer Visa cards funded by stablecoins, with transactions now able to settle on‑chain through Visa via Lead Bank. Bridge‑enabled cards are currently live in 18 countries, with plans to expand to more than 100 markets across Europe, Asia Pacific, Africa, and the Middle East by year‑end. The expansion builds on Visa's stablecoin settlement pilot, which enables issuers and acquirers to settle with Visa using stablecoins over supported blockchain networks. Visa is also evaluating potential support for Bridge‑issued assets as a future settlement pathway for partners.

Global: Visa and Trip.com launch global virtual travel card programme

On 11 March 2026, Visa and Trip.com Group announced a global agreement to make travel booking and payments more seamless, as demand across Asia Pacific continues to recover. Under the partnership, Trip.com Group will introduce a Visa virtual travel card programme, issued through its fintech arm TripLink, to help travel suppliers, hotels, and agencies process payments more efficiently and securely, thereby improving the overall experience for travellers. The programme has already launched in Singapore and will expand to markets including the Netherlands and Hong Kong.

Hong Kong: HSBC and Standard Chartered among first to secure stablecoin licences in Hong Kong

On 13 March 2026, it was reported that HSBC and Standard Chartered are set to be among the first recipients of stablecoin issuer licences in Hong Kong. The banks are expected to be included in the initial approvals, as the Hong Kong Monetary Authority prioritises bank‑led issuers, citing their strong capital positions and role in supporting financial stability. The move forms part of Hong Kong's broader efforts to establish itself as a regulated digital asset hub. The regulator has indicated that only a limited number of licences will be granted initially, following receipt of 36 applications, to ensure stablecoins demonstrate real‑world use cases and robust regulatory compliance.

Iraq: MoneyHash and Wayl partner to support expansion into the Iraqi market

On 23 February 2026, MoneyHash, a leading payment orchestration platform operating in emerging markets, announced a partnership with Wayl, a fintech startup operating an e‑commerce platform in Iraq. The partnership will enable MoneyHash to support businesses navigating Iraq's payment landscape through market‑specific infrastructure and local expertise provided by Wayl. It will allow merchants to access key Iraqi payment methods, including international card schemes, local wallets, and bank‑based options, addressing regulatory and operational complexities associated with market entry. The partnership forms part of MoneyHash's broader strategy to support businesses seeking to establish scalable e‑commerce operations in Iraq and the wider Middle East through collaboration with trusted local partners.

Europe: Green Banana and VR Payment partner to enable BNPL orchestration in Europe

On 23 February 2026, Green Banana, a pan‑European buy now, pay later (BNPL) orchestrator, and VR Payment, a German payment specialist, announced a collaboration to support BNPL orchestration across European payments. The partnership enables merchants to manage BNPL, cards, wallets, and other payment methods through a single, consolidated dashboard. The joint solution centralises transaction data, settlement information, and reporting, thereby simplifying payment management. It aims to support faster market expansion by reducing the operational burden associated with managing diverse payment portfolios across European markets with varying regulatory and consumer requirements.

India: Razorpay announces launch of AI Agent Studio for payments and Agentic Experience Platform

On 12 March 2026, it was reported that Razorpay, an India‑based omnichannel payments and banking platform, had launched an AI Agent Studio for payments and an Agentic Experience Platform at its annual FTX 2026 event. Built using Anthropic's Claude Agent SDK, the Razorpay Agent Studio serves as a B2B marketplace and builder platform for AI agents that perform tasks such as abandoned cart recovery, failed subscription retries, settlement reconciliation, and payment dispute resolution. The Razorpay Agentic Experience Platform introduces conversational AI to simplify merchant onboarding, payment integration, and operational management. Together, the launches signal Razorpay's shift towards AI‑driven payment infrastructure.

Belgium: KBC partners with Taurus for digital asset custody to support regulated crypto offering

On 10 March 2026, Taurus, a Switzerland‑based fintech company providing enterprise‑grade digital asset infrastructure, announced that it had been selected as the digital asset custody partner for KBC. KBC is one of Belgium's leading bank‑insurance groups, and the partnership will support KBC's regulated crypto trading offering. Using Taurus‑PROTECT, Taurus' banking‑grade custody platform, KBC will enable private investors in Belgium to buy and sell Bitcoin and Ether. Trading will be available through Bolero, KBC's self‑directed investment platform. The launch makes KBC the first Belgian bank to offer crypto trading within a fully regulated banking framework, operating on an execution‑only basis and in line with the EU's MiCAR framework.

Global: Merchant Risk Council publishes 2026 Global eCommerce Payments and Fraud Report

On 18 March 2026, the Merchant Risk Council (MRC) published its 2026 Global eCommerce Payments and Fraud Report, developed in collaboration with Visa Acceptance Solutions and Verifi. The report draws on insights from 1,278 merchant professionals across 37 countries and analyses global trends in emerging payment technologies and evolving fraud threats.

The report assesses five key areas: payment acceptance; payment metrics and tactics; fraud management strategies and challenges; fraud management metrics and tactics; and post purchase fraud and abuse. These findings provide benchmarks and practical guidance to help merchants optimise payment performance and manage fraud risks in an increasingly complex global market.

Key findings include:

• 43% of merchants now accept real time payments, reflecting rapid growth in emerging payment methods;
• 63% of merchants are actively exploring or planning the adoption of agentic AI payments;
• 72% of merchants use one or more forms of payment tokenisation, highlighting its increasing importance for payment security and optimisation;
• 64% of merchants report rising levels of first party misuse, with one quarter seeing increases of 25% or more; and
• Merchants experienced an average of 3.7 different fraud attacks in 2025, down from 4.2 in the previous year.

Global: Mastercard identifies key payments trends shaping global commerce in 2026

On 27 February 2026, Mastercard published its Payments Trends Navigator, highlighting five key trends shaping the global payments and banking landscape in 2026.

Key payments trends highlighted in the report include:

• Stablecoins becoming core financial products: Stablecoins are moving beyond speculative use and seeing accelerating global adoption as core financial products. Their ability to enable near instant, 24/7, low cost settlement and programmable finance makes them particularly well suited to cross border transactions.
• Global expansion of B2B card acceptance: Barriers to B2B card payments are eroding due to digital innovation, economic pressures and changing customer expectations. Expanding B2B card acceptance presents a significant opportunity to streamline transactions and unlock value for buyers and suppliers.
• Growth of Banking as a Service (BaaS) models: Rapid growth in BaaS is reshaping how financial products are built and delivered, blurring the lines between banks, fintechs and non financial firms. Using BaaS, incumbent banks can extend reach, monetise balance sheets and data, and avoid disintermediation.
• Shift from proprietary platforms towards interoperable payments ecosystems: Banking is moving away from closed, institution centric systems towards open, interoperable ecosystems based on multi party collaboration, API frameworks and shared data models. This shift is driven by demand for seamless, digitally enabled experiences and competitive pressure.
• Rising AI driven cyber threats: Cybersecurity is increasingly an AI versus AI challenge as attackers and defenders deploy autonomous agents at machine speed. While agentic AI allows real time monitoring and response, it also enables more sophisticated attacks. [View source.]

Send Print Report

Related Posts

• UK securitisation reform: A more proportionate second act
• FCA consultation on simplifying the rules for investment advice
• UK FCA publishes examples of good and poor practice for using labels under the UK Sustainability Disclosure Requirements

Latest Posts

• South Carolina enacts age-appropriate design code with significant requirements for online platforms
• The Payments Newsletter including Digital Assets & Blockchain, March 2026 See more »

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.
Attorney Advertising.

©
Hogan Lovells
2026

Written by:

Hogan Lovells Contact + Follow Charles Elliott + Follow Virginia Montgomery + Follow

PUBLISH YOUR CONTENT ON JD SUPRA

• ✔ Increased readership
• ✔ Actionable analytics
• ✔ Ongoing writing guidance Join more than 70,000 authors publishing their insights on JD Supra

Start Publishing »

Published In:

Blockchain + Follow Central Bank Digital Currency (CBDCs) + Follow Cross-Border Transactions + Follow Cryptoassets + Follow Digital Assets + Follow Financial Conduct Authority (FCA) + Follow Financial Stability Board + Follow FinTech + Follow Fraud + Follow New Legislation + Follow Payment Systems + Follow Payment Systems Regulator (PSR) + Follow Regulatory Oversight + Follow Regulatory Reform + Follow Regulatory Requirements + Follow Reporting Requirements + Follow Stablecoins + Follow Finance & Banking + Follow International Trade + Follow Science, Computers & Technology + Follow more

Hogan Lovells on:

Solve with 2Captcha

Solve with 2Captcha