Review of Retail Payments Regulation Summary of Submissions to the Review of Merchant Card Payment Costs and Surcharging Consultation Paper

Introduction

The RBA received written submissions from 174 individuals and organisations to its Consultation Paper on the Review of Merchant Card Payment Costs and Surcharging, released on 15 July 2025. 148 submissions were published on the RBA website in September, with the remaining submissions provided to the RBA on a confidential basis; some organisations provided a confidential submission as well as a public submission. In addition, the RBA conducted verbal discussions with some stakeholders who were not in a position to provide written submissions.

Submissions came from a broad range of stakeholders including consumers, small businesses, large corporations and government entities. Payments industry stakeholders included card networks, domestic and international issuers, acquirers, payment gateways and wallet providers.

The submissions expressed views on the effects that the proposals in the Consultation Paper could have on everyday transactions, business models and competitive dynamics in the payments industry. Different stakeholders have divergent views on many issues, including how costs should be allocated and the flow-on consequences of the proposals. Staff have held over 40 stakeholder meetings to date and are following up with further questions to relevant stakeholders.

Stakeholders provided data and other evidence, either as part of their submissions or through follow-up engagements. Some stakeholders proposed alternative approaches on specific proposals or as an overall package. Other stakeholders proposed areas where staff could seek further information to inform recommendations to the Payments System Board (PSB).

Staff have considered, and continue to consider, submissions and additional information by reference to the PSB’s legislative mandate of controlling risk in the financial system, promoting the efficiency of the payments system, and promoting competition in the market for payment services consistent with the overall stability of the financial system.

This document provides a summary of the submissions and additional information received to date (where that information is not confidential).

To give due consideration to this substantial body of information and their policy implications, the RBA has decided to extend the time for concluding the Review of Merchant Card Payment Costs and Surcharging until March 2026.