Public Interest Framework for a Successful Account-to-Account Payments System July 2025

Introduction

This paper provides a high-level conceptual framework for a successful account-to-account (A2A) payments system that serves the public interest – that is, benefits society as a whole. This analysis has been undertaken to underpin the work by the industry, together with the RBA and Treasury, to develop a vision and plan for the future of the A2A payments system.¹

The A2A payment system is broad in scope, encompassing various payments infrastructures and customer-facing payments services that facilitate payments on behalf of Australian end users (including households, businesses and governments).²

In the RBA’s view, the public interest for A2A payments can be best served by the payments industry delivering a system that meets the needs of end users at large. A centrepiece of the framework is therefore the achievement of key end-user objectives. Achieving these objectives requires consideration of the end-to-end A2A payments experience, which depends on the performance of the relevant payments infrastructures (including all payments clearing ‘rails’ and settlement systems) as well as customer-facing payments services.

A successful A2A payments system would achieve the end-user objectives on an ongoing basis. Because end-user expectations and external conditions evolve, the ecosystem will need to adapt and innovate to continue to meet end-user objectives over time. Considering the long-term structural forces affecting payments (i.e. those likely to have an impact beyond 2030) in the work to determine a vision will be important for ‘future proofing’ the A2A payment system as much as possible.

Finally, this analysis – which is focused on the public interest considerations for determining the A2A payment system vision – does not consider the system’s transition to the future state. The transition phase may involve some short-to-medium term trade-offs in pursuit of the end-user objectives. Prioritisation and sequencing issues can be assessed further during the work to develop a plan for achieving the vision.

The Conceptual Framework

From a public policy perspective, the ultimate mark of success for a payments system is that end-users trust the system and derive value from it for their everyday economic activities (Figure 1, top layer). This can be realised by the A2A payments system continually providing end users (encompassing households, businesses and governments) widespread access to payments options that are capable of meeting their needs, and that are cost-effective, reliable and safe (Figure 1, middle layer). Achievement of these objectives requires the entities involved in the system – industry bodies, participants and the public sector – to also put in place the necessary foundational (or ‘enabling’) elements, including governance and coordination arrangements, competitive and innovative behaviours, and clear and proportionate policy or regulatory settings (Figure 1, bottom layer).³

The end-user objectives within the framework are outlined in more detail in Table 1. All of these objectives need to be present for the A2A system to be successful. However, trade-offs can be involved – for instance, full reliability in payments could be expensive to deliver, while newly introduced capabilities might be immature from a safety perspective (e.g. higher data privacy or scam risks). Finally, while these objectives have been defined generally and can be considered enduring (i.e. they apply across time periods), end-user expectations and external conditions will naturally evolve over time as risks, technologies and societal attitudes change. The entities involved in the system will therefore need to be able to adapt and innovate to deliver these objectives on an ongoing basis (see below).

The foundational elements within the framework are outlined below and in Table 2. These elements should not be considered static – the entities responsible will need to adapt and innovate as circumstances evolve and challenges arise, to deliver ongoing trust and value to end users.

• Governance and coordination by the A2A scheme owner/s, as well as other industry bodies involved in A2A arrangements, is vital to the success of the A2A payment system. A key driver of effective governance is the mandate of the industry bodies. Mandates should be designed with the ongoing achievement of end-user objectives in mind, which usually involves the inclusion of public interest considerations (such as competition, efficiency, safety and resilience) in addition to private objectives such as commercial sustainability. Another important aspect of governance is scheme participation requirements and rules. These should be clear, transparent and proportionate, effectively address all risks to participants and to the reliability and safety of A2A services for end users, while also permit fair and open access for new entrants. The application of appropriate regulatory standards could help the system to meet these aims. The effective implementation of industry or scheme standards, rules and procedures is crucial to managing key risks or achieving desired efficiencies across the system. It is thus important that bodies put in place mechanisms to monitor compliance with the requirements, and periodically evaluate whether they are achieving their purpose or need adjustment. For instance, arrangements to deliver reliability or safety should be continually re-assessed against outcomes, evolving risks and changing external conditions.
• The network nature of payments means that a successful A2A payment system requires not only an effective scheme and well-functioning infrastructure, but also a viable and competitive ecosystem of participants to implement all scheme arrangements and rules and deliver trusted and valued front-end services to end users. Participants also need to come together to coordinate on shared payments innovations that help achieve end-user objectives and implement these in a timely and effective way.
• The Government and public authorities also have a role to play in setting public expectations around the strategic direction of the A2A payment system and in regulating participants and industry bodies. Proportionate regulation of individual participants provides assurance that various risks are adequately managed, payment services are secure and end users (particularly consumers) are protected. Regulation and oversight of payments schemes, industry bodies and infrastructure arrangements is also important for competition, efficiency and safety in the A2A payments system – public interests that are closely aligned with the end-user objectives. The RBA’s longstanding regulatory principles for competition and efficiency in the card payments system and the international Principles for Financial Market Infrastructures (PFMI) can provide guidance in this respect.