Code of conduct for indirect access providers

A voluntary code of conduct has been developed for indirect access providers, by the subscribing organisations, in consultation with the Payment Systems Regulator (PSR). You can view the full code, by following the link below

Administered by Pay.UK, the code reflects the Payments Services Directive (PSD2) relating to indirect access to designated payment systems, and addresses concerns around the commercial access arrangements provided to PSPs requiring indirect access services.

About the code

The code sets out standards of best practice for key elements of the commercial arrangements between indirect access providers and indirect PSPs, and aims to improve the experience of the latter by clearly outlining the responsibilities of organisations subscribed to the code.

Specifically, the code is designed to meet the requirements of indirect PSPs for:

  • Clarity on the contractual arrangements that govern the supply of indirect access services they receive
  • Security of the supply of indirect access
  • Confidentiality of commercially sensitive information shared with indirect access providers
  • Support in establishing indirect access and switching between providers
  • Appropriate and timely communication between indirect access providers and indirect PSPs regarding the availability of services and planned changes.

Who the code applies to

The following indirect access providers have subscribed to the code:

  • Barclays
  • ClearBank
  • HSBC
  • Lloyds Banking Group
  • NatWest Group
  • The Bank of London

An indirect access provider may choose to become a code subscriber if it is registered with, or authorised by, the Financial Conduct Authority (FCA) for activities that include provision of payment services.

Any indirect access provider wishing to apply to Pay.UK to be registered as a code subscriber can contact the code administrator at

Code beneficiaries

Code beneficiaries are indirect PSPs that have an agreement for indirect access services to one or more in-scope regulated payment system with an indirect access provider that is a code subscriber.

To qualify as a code beneficiary, an indirect PSP must also be:

  • Registered with, or authorised by, the UK Financial Conduct Authority
  • Using indirect access services to provide its customers with eligible payment services.

Code administration

As the code administrator, Pay.UK is responsible for administrating all aspects of the code, as well as having responsibility for reviewing its effectiveness. This is done through compliance monitoring, engaging with stakeholders, including the PSR, and via an annual self-certification process.

Monitoring also includes seeking feedback from interested stakeholders via a Code Consultative Group, established to allow code beneficiaries to meet to provide their views on the effectiveness of the code.

The Code Consultative Group is open to any PSP with an agreement for the provision of indirect access services with one of the code subscribers (currently Barclays, ClearBank, HSBC, Lloyds, NatWest Group and The Bank of London).

If you need more information on the code, or are interested in attending future meetings, or receiving minutes, then please contact us at

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