RBA Review of Payments System Regulation: Where 75 Submissions Point

In October 2026 the Reserve Bank of Australia published its Summary of Submissions to the Review of Payments System Regulation Issues Paper; the document itself is dated 6 October 2026. Seventy-five stakeholders answered the Issues Paper released on 25 June 2026. The RBA published 56 of those submissions in August and received the rest on a confidential basis, with some stakeholders lodging both a public and a confidential version. The RBA intends to publish a list of regulatory priorities by the end of 2026 and to begin further consultation on the prioritised issues from mid-2027.

The legal ground under the review has moved. The Payment Systems (Regulation) Act 1998 (PSRA) was amended by the Treasury Laws Amendment (Payments System Modernisation) Act 2025, and the RBA’s March 2026 conclusions on card surcharging said those amendments brought three-party card networks and buy now, pay later (BNPL) services clearly within its regulatory perimeter. Much of the summary concerns firms that sat outside the RBA’s card standards: mobile wallet providers, American Express, BNPL providers, integrated commerce platforms, gateways and non-bank payment service providers (PSPs) in account-to-account (A2A) payments.

The summary binds no one, and the RBA says it will weigh the submissions together with other information and analysis. For a reporting or compliance team the useful reading is narrower: which issues could turn into information requests, designation decisions or standards for your business, and what evidence you hold today if the RBA asks for it.

Related reading: RBA Payments System Board June 2026: What Australian PSPs Must Act On

The Review of Payments System Regulation calendar

Two RBA processes now run side by side: the 2026 review, which is still at the evidence stage, and the card-cost reforms concluded in March 2026, which are already being implemented. The operative dates from both:

• 25 June 2026: Issues Paper released.
• 7 August 2026: submissions closed.
• August 2026: 56 non-confidential submissions published.
• August to September 2026: stakeholder engagement on the submissions.
• 1 October 2026: the March 2026 card reforms took effect under the Payment Systems (Regulation) Standards (Merchant Card Payment Costs and Surcharging) Variation 2026, lifting the RBA’s prohibition on no-surcharge rules for eftpos, Mastercard and Visa and lowering interchange caps on domestic-issued cards.
• 6 October 2026: date on the summary of submissions.
• 30 October 2026: first quarterly publication of interchange and scheme fees by the designated card networks and of merchant service fees by large acquirers, covering July to September 2026.
• End of 2026: RBA list of regulatory priorities.
• 30 January 2027: first publication of interchange pass-through by large acquirers.
• 31 January 2027: end of the ACCC authorisation for the A2A Payments Roundtable process.
• 1 April 2027: interchange caps on foreign-issued card transactions, new merchant statement content (from the first full statement period starting on or after that date) and the card networks’ Scheme Fee Roadmaps.
• Mid-2027: further consultation on prioritised issues.
• 2028: conclusions, according to the timeline on the RBA’s review page.

One detail in the Issues Paper changes how the next quarter works. From October 2026 the RBA said it would concentrate on assessing the evidence already submitted and would engage further with stakeholders only where clarification or more information would help it, or where it otherwise saw fit. The stakeholder-led phase has ended, and further engagement is at the RBA’s initiative. The Payments System Board’s August 2026 meeting fell inside the engagement window; our RBA Payments System Board August 2026 outcomes note covers what it reported.

What a summary of submissions can and cannot tell you

The document is a structured digest of stakeholder views, organised under the five topic chapters of the Issues Paper: merchant choice in payments; mobile payments, non-designated card networks and BNPL; A2A payments; cryptography and fraud prevention; and other issues. It records no RBA findings and no preferred options. Reading “many stakeholders stated that the RBA should prioritise” as an RBA position misreads the paper.

The summary does carry a usable signal in its own vocabulary. Each section grades support with a fairly consistent ladder: “many stakeholders”, “some support”, “a few stakeholders”, “a small number”. Those words describe submissions, and submissions are self-selected. A chapter where merchants and smaller PSPs wrote in heavily can read as overwhelming support even when the parties who would bear the cost of regulation are fewer in number.

The coverage is also incomplete by design. The RBA summarised submissions and additional information received to date only where that information is not confidential. The RBA’s submissions page records 25 confidential submissions, some from entities that also lodged public submissions, so the public record of 56 submissions understates what the RBA has in front of it. Confidential evidence on costs, fees or fraud is part of the record the RBA will weigh, even though other participants cannot see it.

The amended PSRA: data powers before any designation

The Treasury Laws Amendment (Payments System Modernisation) Act 2025 (No. 46, 2025) received assent on 19 September 2025, and its Schedule 1 amendments to the PSRA commenced on 19 December 2025. The compiled Act now in force (Compilation No. 7) frames the review in three steps.

First, the perimeter. Section 7A defines a payment system as an arrangement under which payments are made or funds transferred, or under which messages are transmitted or received that effect, enable, facilitate or sequence payments. A participant is a constitutional corporation that operates, administers or participates in the system, or provides services that enable or facilitate the system’s operation, the making of payments under it, or the transmission of payment messages under it. That second limb is wide enough to raise the question for gateways, wallet providers and platforms that never hold customer funds.

Second, designation. Under section 11 the RBA may designate a payment system, or a class of payment systems, by legislative instrument if it considers designation to be in the public interest. Section 8 tells the RBA what “public interest” means: the desirability of payment systems being financially safe for participants, efficient and competitive, and not materially causing or contributing to increased risk to the financial system. The heavier powers in section 10(2), access regimes, standards, dispute arbitration and directions, attach to designated payment systems. The Minister holds a parallel route under section 11B to designate a system as a special designated payment system on national interest grounds.

Third, information. Section 26(1) allows the RBA to require a participant in a payment system to give it information relating to the payment system and its participants, whether or not that system is designated. Refusing or failing to comply is an offence under section 26(3A) and a civil penalty provision under section 26(3B), each carrying 200 penalty units, and section 26(4) treats a continuing refusal as a further offence for each day it continues. The RBA’s March 2026 card package already plans to use information-gathering powers: under Policy 13 it intends to collect quarterly merchant service fee data from acquirers, with a first reporting period of July to September 2026.

Non-designation therefore limits what the RBA can impose, while leaving its power to ask for information intact. My reading is that the phased approach some submitters proposed for mobile wallets, information gathering first and other measures later if problems are found, fits the Act’s structure, because the first step needs no designation and the second needs a designated system.

Debit routing in wallets and online checkouts

The section on competition across debit card networks opens with the summary’s strongest language: many stakeholders said the RBA should prioritise action on barriers to competition between debit networks for mobile wallet and online transactions. The backdrop comes from the Issues Paper. Around 92 per cent of debit cards issued in Australia are dual-network debit cards (DNDCs). At the end of December 2025 large acquirers reported that least-cost routing (LCR) for online transactions was available to 97 per cent of merchants, yet only three of 11 large providers had it switched on for most of their merchants.

The submitters’ diagnosis centres on tokens. When DNDCs were first tokenised for wallets and online use, only the international networks could support those form factors, so eftpos was absent when merchants made routing decisions on tokenised transactions, even where their acquirer had enabled LCR. Adding an eftpos token after a DNDC is already represented by a single network token is, on their account, a substantial implementation problem. The same pattern could repeat with passkeys, virtual cards, flexible credentials, Click to Pay and agentic payments if those launch supporting one network token by default.

Proposals included requiring both networks on a DNDC to be fully provisioned in every form factor, mobile wallets and online included; setting implementation timelines for large acquirers and PSPs; and publishing data on actual routing outcomes. Under the other-issues heading, some merchant representatives went further and asked for a dynamic LCR mandate and for PSPs to be required to offer unblended pricing such as interchange++.

The counter-case came from some card networks, wallet providers, issuers and PSPs. LCR enablement in wallets was improving, and one wallet provider expected every DNDC in its wallet to support eftpos card-not-present transactions by the end of 2026. Some card networks pointed to a fall in online debit net scheme fees after eftpos added online functionality. Some argued that any intervention should target the specific participant controlling a routing capability, and that extending LCR to all mobile and online transactions could cost more than it returns.

The baseline that already applies is easy to overlook. The RBA’s existing expectation is that debit issuers with more than 1 per cent of total debit card transaction value continue to issue DNDCs and provision both networks in every form factor they offer. In the March 2026 Conclusions Paper the RBA said that if issuers do not meet that expectation it would consider consulting on a standard. The debit networks are already designated, so that standard-making path does not depend on where wallets land in the review’s priority list.

Mobile wallets: NFC access, fee opacity and Apple’s reply

By the end of 2025, Apple Pay, Google Pay and Samsung Pay transactions accounted for around 45 per cent of all card payments by number, according to the Issues Paper, which also estimated issuer costs for wallet-initiated transactions at around 2 cents per debit transaction and 0.06 per cent of value for credit. Many stakeholders asked the RBA to prioritise intervention on mobile wallets, particularly Apple Pay.

Their concerns ran along four lines. Device makers that also run wallets can control third-party access to near field communication (NFC) and secure element functionality, and submitters pointed to limited uptake of Apple’s NFC & SE platform in Australia, describing its terms as too onerous or commercially unviable and contrasting them with the fee-free host card emulation access Apple has granted in Europe. Apple Pay fees were said to be unchanged since its launch in Australia despite rising volumes and falling unit costs, and some stated that even large issuers had been unable to negotiate them. Those fees are generally not visible to merchants or consumers, and stakeholders described strict contractual confidentiality requirements around them. Finally, wallets shape how payment methods are presented and routed, which some submitters argued can steer consumer choice between payment rails.

The remedies proposed form a ladder: access to NFC on fair, reasonable and non-discriminatory terms, or on terms similar to Europe’s, extended to wearables; RBA collection and publication of fee information, with contractual restrictions on fee disclosure removed; controls where fees prove not to reflect costs; and a review of Apple Pay’s contractual terms. Some proposed starting with information gathering and monitoring, others wanted price controls alongside NFC access.

Apple opposed wallet-specific regulation. It said Apple Pay is network-neutral and available to all payment institutions in Australia on the same terms, that more than 125 Australian financial institutions support it, and that its NFC & SE platform has been available to authorised developers in Australia since October 2024. It added that its wallet fees have not increased since launch, that it charges a uniform fee regardless of issuer, that its terms do not restrict issuers from offering or steering customers to other payment methods, and that it has no contractual mechanism to raise fees unilaterally. Other stakeholders asked that any access requirement preserve authentication, liability and security controls without forcing every wallet into identical architectures or commercial models.

The wallet debate leaves one point unresolved in the summary: the RBA has not said whether a mobile wallet is, in its view, a payment system it would designate, a participant in the card systems it already regulates, or both.

American Express and the other non-designated card networks

Many stakeholders, particularly four-party networks and issuers along with some PSPs and merchants, said the RBA should treat American Express as a priority. Their case is asymmetry. As a three-party network American Express issues, acquires and runs the network itself, so there is no interchange payment between issuer and acquirer and no interchange regulation. Submitters cited RBA estimates that three-party networks accounted for almost a quarter of credit and charge card transaction value in 2024, and argued that merchant revenue funds rewards that pull cardholder demand towards a card that is materially more expensive to accept.

Submitters made two further points. Some said American Express increasingly relies on third-party acquirers, making parts of its operation resemble a four-party model; they pointed to the UK approach, where transactions involving an additional issuer or acquirer may be treated like four-party transactions. They also linked the issue to 1 October 2026: designated networks were scheduled to move to lower interchange caps from that date, and some noted that American Express had announced changes preventing merchants from surcharging its cards from the same date.

Supporters generally asked for functionally equivalent and proportionate regulation rather than identical rules for every network, with greater transparency of merchant fees, cardholder rewards and network economics, and interchange-equivalent or outcome-based regulation. A small number of stakeholders, including American Express and associations representing the finance and technology sectors, opposed further regulation. They argued that interchange regulation addresses a four-party problem, that American Express provides meaningful competition to four-party networks by offering simpler pricing and a single relationship for acceptance, settlement and disputes, that merchants can decline it, and that the RBA should first monitor the effect of the card reforms.

On JCB and UnionPay the split is about scale. Some issuers and industry associations wanted consistent regulation for networks performing equivalent functions, either for all networks accepted in Australia or once a network passes a materiality threshold. Other issuers, networks and associations said these networks are too small in Australia to affect competition, efficiency or safety, and that regulating them could deter new entrants.

BNPL: fee transparency ahead of fee caps

Support for prioritising BNPL came mainly from merchants and small-business representatives, with a small number of card issuers, other PSPs, card networks and finance industry associations. They cited RBA estimates that BNPL transactions more than doubled over the past five years, and some cited RBA estimates that BNPL merchant fees averaged around 3 per cent in 2025, around three times average four-party card fees. No-surcharge rules imposed by many BNPL providers, they argued, push those costs into general retail prices, and the absence of published merchant fees weakens small merchants’ bargaining position. One card issuer added that consumer protection and fraud risks could grow if AI agents initiate BNPL transactions with less friction.

Supporters generally favoured targeted measures over direct fee regulation: a review of BNPL no-surcharge rules, publication of merchant fees and other data, and consumer protections comparable to four-party card systems. A smaller group, including BNPL providers, opposed further regulation, citing the National Consumer Credit Protection regime that has applied to BNPL since June 2025; one stakeholder also cited an RBA estimate that BNPL was around 2 per cent of Australian retail payments in 2025.

The two regimes answer different questions, and conflating them is the trap in this chapter. Since 10 June 2025, a person engaging in credit activities involving BNPL contracts has needed an Australian credit licence, following the Treasury Laws Amendment (Responsible Buy Now Pay Later and Other Measures) Act 2024; that regime, administered by ASIC, governs credit conduct towards consumers. Merchant fees, no-surcharge rules and competition between payment methods sit under the PSRA. The history explains why the PSRA question is now live: the Issues Paper notes that in 2021 the RBA concluded that requiring BNPL providers to allow surcharging would promote competition and efficiency, but did not regulate because it was uncertain whether BNPL fell within its PSRA powers.

Token portability, integrated platforms and AI agents

Moving tokens when a merchant switches PSP

The RBA issued expectations for the tokenisation of payment cards and storage of primary account numbers in May 2024. They require merchants and PSPs to meet card industry security requirements when storing card information, or to use tokens instead, conditional on token portability and synchronisation. AusPayNet then published a standard for PSP porting of merchant payment-related data, and the RBA expected industry compliance by 1 July 2026. Submitters supporting further action said the standard covers the porting of cardholder data but does not make PSPs facilitate token transfer through decryption and re-tokenisation, so merchants switching away from proprietary gateway or PSP tokens may need to ask customers to re-enter card details. They proposed extending portability to gateway and PSP tokens, setting timing obligations and permitted fees for token migration, and targeting the conduct of specific participants that impose barriers.

A narrower operational fault sits beside portability. After card replacement or a token migration, a merchant can lose access to one of the two network tokens on a DNDC, and with it the ability to choose the routing network. A few stakeholders asked for clearer lifecycle-event information, stronger synchronisation during migrations and issuer-orchestrated synchronisation. Opponents said the AusPayNet standard commenced on 1 July 2026 and its implementation should be monitored first, and schemes and wallet providers asked that portability not weaken token security.

Payments bundled into platforms

Some stakeholders referred to Shopify charging an additional ad valorem fee when merchants use a third-party PSP instead of Shopify’s own payments service, and more broadly to platforms that do not support integration with competing PSPs, do not separate platform fees from payment processing costs, or impose termination charges. Their proposals: prohibit fees for using third-party providers, require equivalent functionality for preferred and non-preferred PSPs, mandate switching-cost disclosure, and unbundle payment processing costs from platform fees. Some platforms, merchant and technology industry associations and a few PSPs disagreed, citing efficiency benefits for small businesses, the security value of a few tightly managed integrations, and switching complexity as an ordinary feature of changing provider.

Agentic commerce

Many merchants, PSPs and issuers raised concerns about AI agents: built-in network or PSP preferences that could undercut merchant routing choice, an extra intermediary adding fees (one stakeholder referred to reports that, in early 2026, merchants would be charged an additional 4 per cent fee when customers used one AI agent to complete a purchase), unclear chargeback liability where an agent may have acted outside its authority, and compromised agents. Despite that list, stakeholders generally proposed that the RBA monitor developments and support industry standards for now, pointing to limited evidence of harm and to existing tools such as the ePayments Code and the RBA’s tokenisation expectations.

Account-to-account payments: access, PayTo and the BECS question

The A2A chapter is the most operational in the summary. Non-bank PSPs and fintechs said eligibility for direct participation in systems such as the New Payments Platform (NPP) is generally aligned with authorised deposit-taking institution (ADI) status, with onboarding that is in some cases costly and opaque, leaving many smaller firms dependent on sponsors. Submissions said sponsored institutions face limited ability to negotiate pricing or service levels, access that can be withdrawn at short notice with limited appeal, few alternative sponsors, and sponsors that compete in the same market while controlling the functionality available to them. Sponsors replied that monitoring indirect participants carries significant operational, compliance and risk-management cost.

Other issues submitters raised: NPP account reach is insufficient for payroll, superannuation, tax and supplier payments; PayTo is unevenly enabled across institutions, with inconsistent limits and gaps in business accounts; there are no industry-wide refund, chargeback and disputed-transaction mechanisms for A2A payments; and governance of industry-wide decisions is unclear. On the Bulk Electronic Clearing System (BECS), submitters said uncertainty over the timing, governance and sequencing of the transition to the NPP risks duplicated investment. The Issues Paper records that AusPayNet removed the June 2030 target end date for BECS in December 2025 and will not set a new date until a roadmap for A2A payments is in place. Our RBA A2A payments vision readiness guide covers the Roundtable’s final vision in detail.

Proposals included greater transparency of sponsorship arrangements, standardised sponsorship conditions such as minimum service levels and appeal pathways, RBA publication of NPP adoption and A2A capability data, and, from some submitters, regulation of wholesale A2A fees for transparency. On competition with cards, submitters listed PayTo fixes, stronger consumer protections for A2A payments, fair access to NFC, wallets and payment-initiation interfaces, and checkout improvements such as common APIs, bank-agnostic hand-offs and standardised QR acceptance.

Some stakeholders argued against RBA intervention for now, pointing to the A2A Payments Roadmap, developed through a Roundtable of AusPayNet, Australian Payments Plus, the RBA and Treasury, which they said is already assessing most of these issues; the ACCC authorisation for that process runs until 31 January 2027. Submitters also noted that the new payments licensing framework may change obligations for direct and indirect participants, including how responsibility is split between sponsors and sponsored PSPs, and that some saw no demonstrated market failure meeting the PSRA threshold. For settlement-account questions sitting underneath sponsorship, see our note on the RBA 2026 RITS assessment and settlement access for PSPs.

Cryptography and overseas card fraud: little appetite for RBA mandates

Many stakeholders considered stronger cryptographic protection a priority for the industry, but fewer wanted the RBA to mandate it. Submitters acknowledged the industry-led Advanced Encryption Standard (AES) Migration Program and cited estimates that around 970,000 payment terminals and 25,000 ATMs may need replacement or upgrade under it. They also flagged possible misalignment between Australian Signals Directorate (ASD) objectives and PCI Security Standards Council requirements. The Issues Paper cites the ASD’s assessment that cryptographically relevant quantum computers could emerge as early as 2030 and become increasingly likely toward 2040.

A small number of stakeholders wanted a regulatory mandate; one industry group proposed an RBA-set and RBA-enforced standard for all critical payment systems, with a regulatory floor for 2030 readiness covering symmetric and asymmetric cryptography, data in transit and at rest, quantum-resistant protection where relevant and full key lifecycle management. Most stakeholders did not support the RBA setting mandatory technical standards, warning of stranded costs and premature lock-in, and the majority of those supporting an RBA role preferred coordination: convening participants, monitoring readiness, aligning domestic and international expectations and setting high-level outcomes or reference timelines.

While submissions regarded fraud as a significant issue for industry and the government, few explicitly supported the RBA prioritising overseas card-not-present (CNP) fraud. Supporters cited 2024 AusPayNet data showing an estimated $454 million of gross overseas fraud on Australian cards, with overseas transactions making up about half of the fraud on these cards despite forming 3 per cent of total transaction value. Submitters noted that the CNP Fraud Mitigation Framework is enforced through AusPayNet’s Issuers and Acquirers Community (IAC) Code Set and so cannot compel overseas participants to apply equivalent fraud controls. Many submissions still did not support prioritisation, favouring international coordination, better data sharing and updates to the ePayments Code or the Scams Prevention Framework.

Scheme fees, outages and the long tail

The other-issues chapter is short but holds two items with reporting consequences. Some stakeholders were concerned that reductions in interchange caps could be offset by higher scheme fees, and asked for more granular or transaction-level fee disclosure, continued assessment of Scheme Fee Roadmap outcomes and measures to stop schemes replacing or relabelling fees. Several stakeholders asked the RBA to act on system-wide resilience, citing more frequent and longer outages for card services, the NPP and Direct Entry, and proposed common minimum resilience and assurance expectations for critical payment infrastructure, regular attestations and industry reporting on tested recovery capability.

The scheme-fee requests sit beside a scope limit the RBA set itself, and the summary does not say how the RBA will treat them against it. The Issues Paper says the review does not intend to revisit issues addressed in the Review of Merchant Card Payment Costs and Surcharging unless substantial new or unanticipated developments arise, or issues that are the subject of current or recent reviews by other regulatory agencies, and that cash availability is handled in separate RBA work. Scheme fee billing already has its own vehicle in the designated networks’ Scheme Fee Roadmaps.

The remaining items each came from one or a few submitters: chargeback and dispute processes that give small businesses no impartial avenue to challenge allegedly fraudulent chargebacks; interoperability and competition in e-conveyancing; delivery standards for digitally transmitted stored value such as digital gift cards; an exemption for salary packaging providers, for whom payments are incidental; and access to cash. In the same chapter, some stakeholders also asked the RBA to weigh the economic sustainability of domestic payments investment, keep regulation technology-neutral and proportionate, and coordinate with other agencies to avoid duplication.

Reading the weight of support issue by issue

The table uses the summary’s own quantifiers. It shows the balance of submissions, which is one input to the RBA’s priority list, and should not be read as a forecast of that list.

My reading of the table is that the debit-routing, wallet and American Express rows combine strong submitter support with an existing RBA thread: the Conclusions Paper had already deferred online and mobile wallet LCR, mobile wallets, American Express, BNPL and e-commerce platforms to this review. That is an interpretation of the record, and the RBA has given no indication of its ranking.

Preparing evidence before the priority list

Because the review is at the evidence stage, the work it creates now is documentary. The submissions name the data sets that proposals would require participants to produce or publish, and the useful exercise for a PSP is checking whether those figures exist, who owns them and whether they reconcile.

• Routing outcomes on DNDC transactions split by form factor (in person, mobile wallet, online, card on file), and the share of merchants with LCR enabled as distinct from merely available.
• Wallet fees paid per transaction by issuers, and the contractual clauses governing their disclosure.
• BNPL merchant fee schedules and any no-surcharge terms in merchant agreements.
• Token migration practice: which tokens move on a PSP switch, the timeline, the fees charged, and how DNDC token pairs are kept in sync after lifecycle events.
• Sponsorship terms for indirect A2A participants: pricing, service levels, notice periods for withdrawal and appeal routes.
• Outage frequency, duration and tested recovery capability for card, NPP and Direct Entry services.

Some fee data is already compulsory under the March 2026 package. Designated card networks publish aggregate interchange and scheme fees, and acquirers processing more than $10 billion of card transactions in Australia annually with direct merchant relationships publish merchant service fees, under standards made under section 18, which bind participants in designated systems. Separately, the RBA intends to collect quarterly merchant service fee data from acquirers and says it will consult relevant acquirers on the reporting deadline. The wallets, BNPL services, three-party networks and platforms that much of the summary discusses are not designated systems.

Frequently Asked Questions

We operate a payment gateway and never hold customer funds. Can the RBA’s information powers reach us?

Possibly. Section 7A(2) of the PSRA treats a constitutional corporation as a participant if it provides services that enable or facilitate the transmission or receipt of messages that effect, enable, facilitate or sequence payments under a payment system, and the definition does not depend on holding funds. Whether a particular gateway meets it is a legal question on its facts, including whether the firm is a constitutional corporation. The summary does not say the RBA intends to issue information requirements to gateways.

Does the 1 October 2026 change stop merchants surcharging American Express or BNPL?

The RBA’s change lifts its own prohibition on no-surcharge rules for the designated networks, eftpos, Mastercard and Visa. American Express and BNPL providers are not designated, so whether their transactions can be surcharged depends on their own rules and merchant contracts. The summary records stakeholders noting that American Express announced changes preventing merchants from surcharging its cards from 1 October 2026, and that many BNPL providers impose no-surcharge rules. The Conclusions Paper also said the RBA could recommend that the Government legislate a ban if surcharging continued on designated cards after the prohibition was lifted.

If the RBA collects our fee data under section 26, can it publish that data?

The Act’s own authorisation in section 26A covers use of the information for the purposes of the Act and disclosure to a nominated special regulator, and the note to section 26(1) points to the secrecy requirements in Part VIII of the Reserve Bank Act 1959. The fee publications in the March 2026 card package work differently: they are obligations on the designated card networks and large acquirers to publish their own data under the RBA’s standards.

If we comply with the AusPayNet portability standard, have we met the RBA’s tokenisation expectations?

Not necessarily. The RBA’s May 2024 expectations are conditional on token portability and synchronisation, and the Issues Paper notes that the AusPayNet standard focuses on a standardised process for porting merchant payment-related data, with stakeholders still reporting difficulty porting tokens across PSPs. Compliance with the data-porting standard and the state of token portability are separate questions.

Is RBA designation the only route to binding rules for a wallet or BNPL provider?

The Act provides two routes outside RBA designation. Under section 11B the Minister may designate a payment system as a special designated payment system in the national interest, after consulting the RBA and each special regulator, and under section 11D may nominate special regulators to exercise powers over it. Separately, section 30A lets the RBA accept a written enforceable undertaking from a participant in a payment system whether or not the system is designated. A wallet provider that is a participant in the already-designated eftpos, Mastercard or Visa systems could also be reached by a new or varied standard for those systems, because section 18 standards bind participants in a designated payment system and section 18(1B) lets a standard specify the participants or classes of participants to whom it applies. The summary gives no indication that any of these routes is under consideration.

If the RBA designated a wallet or BNPL system, would the existing card standards apply to it automatically?

Designation gives the RBA its section 10(2) powers over the system; the obligations come from instruments made afterwards. The existing standards name the systems they cover: Standard No. 1 of 2016 on interchange in the designated credit card schemes, for example, names the MasterCard system designated on 12 April 2001 and the Visa system. Requirements for a newly designated system would need a new or varied standard under section 18, and section 29 requires the RBA to take reasonable steps to inform the system’s participants when it determines or varies a standard.

Related Articles

• RBA Payments System Board June 2026: What Australian PSPs Must Act On: the surcharging and interchange decisions whose implementation runs alongside this review.
• RBA Payments System Board August 2026: A2A, RITS and Cash Outcomes: the Board meeting held while the review submissions were being assessed.
• RBA A2A Payments Vision: A Readiness Guide for Australian PSPs: the Roundtable’s final vision for A2A payments and what it asks of PSPs.
• RBA 2026 RITS Assessment: What It Means for Australian PSPs and Banks: settlement access, which sits underneath the sponsorship debate.
• Australia Finds No Current Case for Retail CBDC: The RITS Tokenisation Consultation: the RBA’s parallel work on tokenised money and RITS.

Key Takeaways

• Treat the end-2026 priority list as the first budget trigger this review can produce for wallet, BNPL, platform or A2A change; the October summary sets none.
• Name one owner for RBA information requests, with documented lineage for fee, routing, token and outage figures.
• Section 11 sets no consultation step of its own: the RBA designates by legislative instrument when it considers designation to be in the public interest, and standards under section 18 attach only to a designated system, so a designation instrument would be the formal signal for a three-party network or BNPL service. A wallet provider that is a participant in the already-designated eftpos, Mastercard and Visa systems could also be reached through a new or varied standard for those systems.
• Debit issuers above the 1 per cent threshold: an evidence pack showing both networks provisioned in each form factor answers the expectation that the RBA has said it would consider backing with a standard.
• PSP-switching projects should budget token re-provisioning separately from the cardholder data port.
• Sponsors and sponsored PSPs: write down pricing, service levels, withdrawal notice and appeal routes now, ahead of both the licensing reforms and any RBA move on sponsorship transparency.
• 1 April 2027 brings foreign-issued card caps, new merchant statement content and Scheme Fee Roadmaps, ahead of the mid-2027 start of consultation on prioritised issues.

Sources and References

• Reserve Bank of Australia, Summary of Submissions to the Review of Payments System Regulation Issues Paper (October 2026): web page and PDF (dated 6 October 2026)
• Reserve Bank of Australia, Review of Payments System Regulation (review page and timeline): https://www.rba.gov.au/payments-and-infrastructure/regulatory-reviews/review-of-payments-system-regulation-2026/
• Reserve Bank of Australia, Review of Payments System Regulation: Issues Paper (25 June 2026): https://www.rba.gov.au/payments-and-infrastructure/regulatory-reviews/review-of-payments-system-regulation-2026/2026-06/pdf/issues-paper.pdf
• Reserve Bank of Australia, Review of Payments System Regulation: Submissions received: https://www.rba.gov.au/payments-and-infrastructure/regulatory-reviews/review-of-payments-system-regulation-2026/2026-06/submissions/
• Reserve Bank of Australia, Review of Merchant Card Payment Costs and Surcharging: Conclusions Paper (March 2026): https://www.rba.gov.au/payments-and-infrastructure/review-of-retail-payments-regulation/2026-03/conclusions-paper/pdf/conclusions-paper.pdf
• Payment Systems (Regulation) Act 1998, Compilation No. 7 (19 December 2025), sections 7A, 8, 10, 11, 11B, 11D, 18, 26, 26A, 29 and 30A: https://www.legislation.gov.au/C2004A00318/2025-12-19/2025-12-19/text/original/pdf
• Payment Systems (Regulation) Standards (Merchant Card Payment Costs and Surcharging) Variation 2026 (registered 14 April 2026, commenced 1 October 2026): https://www.legislation.gov.au/F2026L00434/asmade/text
• Standard No. 1 of 2016 The Setting of Interchange Fees in the Designated Credit Card Schemes and Net Payments to Issuers, Compilation No. 4 (1 October 2026), clause 2.2: https://www.legislation.gov.au/F2016L00836/2026-10-01/2026-10-01/text/original/pdf
• Standard No. 2 of 2016 The Setting of Interchange Fees in the Designated Debit and Prepaid Card Schemes and Net Payments to Issuers, Compilation No. 4 (1 October 2026): https://www.legislation.gov.au/F2016L00837/2026-10-01/2026-10-01/text/original/pdf
• Standard No. 3 of 2016 Scheme Rules Relating to Merchant Pricing for Credit, Debit and Prepaid Card Transactions, Compilation No. 2 (1 October 2026): https://www.legislation.gov.au/F2016L00838/2026-10-01/2026-10-01/text/original/pdf
• Treasury Laws Amendment (Payments System Modernisation) Act 2025 (No. 46, 2025): https://www.legislation.gov.au/C2025A00046/asmade/text
• ASIC, Buy now pay later credit contracts: credit licensing: https://asic.gov.au/regulatory-resources/credit/buy-now-pay-later-credit-contracts-credit-licensing/

Before the RBA publishes its priority list

The summary closes the evidence-gathering phase without narrowing the field: the record still covers eleven issue areas, and the RBA has said only that it will choose among them by the end of 2026. The review has added no filing or publication duty so far. The amended PSRA does let the RBA ask for underlying data before it decides whether to regulate, so the evidence a firm holds matters before any rule exists.

The artifact worth producing this quarter is an issue-by-issue exposure map: each of the summary’s chapters against your products, the data you would be asked for, and its owner. Check it against the RBA’s priority list when it is published by the end of 2026, and against the consultation papers due from mid-2027.

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