Positioning
OpenPISP — An Open Payment Scheme for the UK Market
One-page summary
Faster Payments and Open Banking together provide everything a payment scheme needs: real-time settlement, bank-to-bank money movement, and a regulatory framework for payment initiation. The technical case for building on these rails rather than alongside them is straightforward. The reason it hasn’t happened is not technical.
Every previous attempt at a bank-to-bank payment scheme has been led by a bank consortium or a commercial operator. That structural choice shaped what those schemes became: the incentives of the governing participants and the incentives of the network were never fully separable. Merchants and independent payment firms were being asked to build on infrastructure governed by their competitors. Most declined.
OpenPISP is built differently. The protocol is open. The Scheme Authority is a non-commercial body with no financial interest in transaction outcomes, funded by membership fees rather than transaction revenue. No single participant controls the rules. That separation — between protocol governance and commercial operation — is what previous attempts did not have.
Every new PISP that joins expands the addressable market for every existing PISP. A well-capitalised entrant who builds on the protocol strengthens the scheme rather than threatening incumbents.
The first client strategy targets contexts where the cold start solves itself: either the merchant controls the payer relationship closely enough that enrollment follows naturally from adoption, or the product is compelling enough that payers will tolerate the friction to access it. The first category is structurally more reliable.
Banks are the natural payer-managing entities. A bank operating as a payer-heavy PISP earns on every transaction its customers make, without acquiring a single merchant. The commercial model is designed to make that an attractive position.
PISPs do not hold funds. FCA authorisation is required — the scope is correspondingly limited — and is a known step in the programme.
What exists today
A reference implementation demonstrating the complete protocol: PISP coordination, dispute resolution end-to-end, a Scheme Authority service, and merchant and payer portals — tested against a live Open Banking sandbox. It is designed as a demonstrator of protocol behaviour and as a foundation any organisation could build a PISP implementation from. It is not, and was never intended to be, a production deployment.
A series of eight papers covering the structural diagnosis, the protocol design, and the commercial architecture — available on request.