The document provides guidance for organisations operating within the regulatory environment of the UK and either applying for, or providing, services covered under Regulation 105 of the PSRs 2017.

The EPA acknowledges that the good practice guidelines provide a useful collation of current information and requirements. Because access to banking is such a fundamental requirement of any licensed institution, the EPA has cooperated with UK Finance (UKF) in the production of these good practice guidelines. In the twelve months it has taken to produce them, the EPA has provided regular input and constructive challenge based on the experiences of its 140 members, 50% of which are regulated companies.

The EPA will continue to be collaborative in the ongoing review of the impact of this document and will make recommendations on areas that could be enhanced or amended within the guidance document.

However, the EPA believes that the problem of limited access to banking, whether to do with the companies applying for the account or the banks providing it, remains considerable. Hundreds of companies are without a bank account, and many more have them withdrawn at short notice. So the EPA is developing a standardised approach to how organisations can gain access to bank accounts. The UKF good practice guidelines do not, unfortunately, provide practical techniques or strategies to firms who are seeking access to bank accounts nor does it provide information on which account services are offered by which credit institutions.

Over the last four years the Emerging Payments Association (EPA) has highlighted how it is becoming increasingly difficult to open a bank account if you are a business, PSP or financial institution. The EPA has also highlighted the increased level of de-risking by UK banks that is shutting the accounts of such businesses, often, we believe, in order to reduce the banks’ levels of exposure to risk and improve their margins.

To help address this problem, within the next three months the EPA will publish a ‘Guide to Bank Account Access’ which will contain a description of all the organisations providing access to bank accounts or settlement account services to UK PSPs. It will provide pragmatic practical help guidance that should be useful for both banks and those opening accounts with them, whether they are FinTechs or payments businesses.

‘We’ve supported UKF in the production of what is a pretty good starter for ten,’ says Tony Craddock, Director General of the Emerging Payments Association. ‘It’s like the specification document for your new lightweight drone – it is interesting, but not as helpful as a practical set of guidelines on how to fly the thing. But UKF’s hands are tied. Ours are not. Our Guide to Banking Access sets out to make the job of opening and keeping a bank account much more straightforward.

EPA members call upon the regulator and government to take an active role in supporting applicants to gain access to payment account services within the UK, whether through building upon regulation already applied to the market or by providing a strong direction on how the market should operate in order in order to constructively help applicants.
The EPA also encourages that Bank of England to implement their enhancements to the U.K.’s Real-Time Gross Settlement (RTGS) swiftly and recommends that Bank of England goes even further to open up greater direct access to settlement accounts. The EPA commends the Bank of England for continuing to develop an RTGS service which provides access for a wider number of firms.

Andrea Dunlop, Chair of the EPA Advisory Board, comments ‘It’s clear that challenges remain to gain access to a bank account in the UK, and that there is limited appetite from banks to provide services to non-bank PSPs. We still need for the industry to provide a more practical guide to help companies navigate this challenging space, as well as some options on how we could improve this situation in the UK. After all, with Brexit around the corner, it’s important that companies based here or wanting to setup in the UK feel that UK Banking is open for business.’