Bank of England updates payment systems governance statement and shifts overseas code disapplication to section 191 directions

The Bank of England has updated its supervisory statement on governance for recognised payment system operators and published amendments to its Recognised Payment Systems Code of Practice that took effect on 12 June 2026. The main change is how the framework treats firms incorporated outside the UK. Instead of the Bank notifying a firm that a part of the code will not apply, the code now disapplies the relevant part only where the Bank issues a direction under section 191 of the Banking Act 2009. Under the updated governance statement, the Bank will assess overseas recognised payment system operators on a case-by-case basis, taking into account factors such as their systemic importance in the UK and whether the home-country regulatory and supervisory framework delivers equivalent governance outcomes. Where the Bank decides that an overseas operator should not be subject to its requirements and expectations, it expects to specify the non-applying part of the code in a section 191 direction. The same section 191 approach has also been written into the operational resilience and outsourcing and third-party risk management parts of the code. The governance framework itself continues to require recognised payment system operators to act as systemic risk managers and to maintain clear arrangements on board accountability, risk management, conflicts of interest and performance review, with the supervisory statement setting more detailed expectations on board independence and committee oversight.