UK and Europe

AI strategy enters the delivery phase

The UK’s AI agenda is moving beyond ambition and into execution. The Scottish Government’s AI Strategy for 2026 to 2031 reflects this shift, with a focus on infrastructure, skills, and responsible adoption.

This signals a broader political recalibration. The UK still aims to lead as a pro-innovation economy, but credibility now depends on delivery as global competition intensifies.

Devolved strategies introduce greater flexibility but also create questions around coordination. As AI adoption accelerates across regulated sectors, differences in approach across the UK are likely to become more visible.

Agentic commerce forces a policy response

The concept of agentic commerce, where AI systems initiate and complete transactions independently, is moving quickly from theory to policy concern.

This is where AI and payments converge most directly. When machines transact, traditional regulatory assumptions begin to weaken. Consent becomes less visible, authentication becomes indirect, and liability becomes unclear.
Current frameworks are built around human decision making. They are not designed for autonomous systems operating in real time.

The next phase of regulation will need to address who is responsible when AI fails, how consent is captured, and what safeguards are required when payments are embedded into automated processes.

Open banking becomes economic policy

New estimates placing the value of open banking at up to £43 billion annually reinforce its role as a core component of UK economic policy.

This carries political weight. In a post-Brexit environment, the UK is under pressure to demonstrate competitive advantage. Open banking is one of the clearest examples of domestic success.

The direction is toward expansion into open finance. This will bring more sectors, more data, and greater complexity into scope.

The focus should now shift toward building stronger consumer case studies and deepening understanding and utilisation of open finance, positioning the UK to lead in this next phase.

The FCA signals earlier and sharper intervention

The UK’s Financial Conduct Authority is adopting a more active posture. Recent signals point to earlier and more decisive intervention.

Fraud, particularly authorised push payment (APP) scams, remains a central concern. More broadly, payments are now treated as critical infrastructure with higher expectations around resilience and oversight.

Political pressure is a key driver. Consumer harm in payments is highly visible and tolerance for failure is low.

Supervision is becoming more proactive. Firms are expected to anticipate risks rather than respond after the fact.

United States

AI-driven commerce accelerates

In the US, AI-driven commerce is advancing rapidly. Autonomous systems, embedded decision making, and AI-powered financial tools are becoming more widespread.

Large technology platforms are driving this change through scale and integrated ecosystems.

The policy response is still developing. Key issues include liability, consent, and data governance.

As in the UK and Europe, payments are central to these debates. The difference is that regulation is following innovation rather than guiding it.

A fragmented but converging regulatory path

The US payments regulatory landscape remains fragmented compared to the UK.

There is no single open banking framework and progress toward standardisation is uneven. Despite this, the overall direction is similar.

There is increasing scrutiny of large technology firms, growing interest in real time payments, and gradual movement toward data sharing frameworks.

The UK is building systems deliberately. The US is adapting to systems that are already in place.

Geopolitics

Global dynamics are becoming more relevant to domestic policy.

Tensions involving the US and Iran, alongside wider instability, are reinforcing the role of payments infrastructure in sanctions, financial control, and cross border restrictions.

Payments are no longer politically neutral. They are part of how states exercise influence.

At the same time, regulatory divergence is becoming clearer. The UK is positioning itself as pro innovation but rules based. The US remains market-led. The EU continues to take a more prescriptive approach.

This divergence will shape how financial systems connect and where friction emerges.

Key takeaways

With the arrival of spring, the policy environment is becoming more active and politically visible, with greater focus on how financial systems operate in practice. AI, open banking and embedded finance are now central to live regulatory debates.

In the UK, earlier intervention and stronger state involvement are emerging, while the US continues to innovate at pace. Set against a complex geopolitical backdrop, payments policy is increasingly shaped by political priorities, linking infrastructure, regulation and strategy more closely.

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