The Rails Are Now in Play: What the RBA's 2026 Payments Regulation Review Means, by the Numbers

By Mark Townley, Founder and Managing Director, Artipi Payments Advisory

On 25 June 2026 the Reserve Bank of Australia opened the most consequential payments policy exercise in a decade. Its new Issues Paper launches the Review of Payments System Regulation, and unlike the targeted surcharging review that concluded in March, this one is deliberately broad.

Amendments to the Payment Systems (Regulation) Act 1998 have widened the RBA's remit to capture payment systems and participants that previously sat outside its reach. Written submissions close on 7 August 2026, regulatory priorities are due by the end of the year, and deeper consultation on the chosen issues follows by mid-2027.

To understand what is at stake, it helps to start with how Australians actually pay.

The shift, by the numbers (RBA data):

• Australians made around 730 electronic transactions per person in 2022/23, more than double the roughly 330 a decade earlier.

• Cards carry about three-quarters of consumer transactions by number; debit, not credit, dominates everyday spending.

• Card payments made through a mobile wallet rose from about 10 per cent in early 2020 to close to 40 per cent by the June quarter of 2024.

• The NPP processed more than 1.3 billion transactions worth over $1.5 trillion in 2022/23, yet still handles only around a quarter of account-to-account payments by number.

• Issuer interchange revenue is expected to fall by about $660 million a year once the card reforms take effect on 1 October 2026.

The shift has been lopsided

Australia is now one of the most digital payment markets in the world, but the change has not been even. What has shifted most is not the card itself but how it is presented. The share of card transactions made through a mobile wallet climbed from roughly 10 per cent in early 2020 to 25 per cent by early 2022, 35 per cent by mid-2023 and close to 40 per cent by mid-2024.

Debit cards are tapped through a phone more often than credit cards. The card network did not lose ground; it migrated onto the device, and in doing so became faster, more secure through tokenisation, and more deeply embedded in the phone people already carry.

That single fact frames the central tension of this review.

Account-to-account: rising, but from the slow lane

The New Payments Platform is genuinely growing. It processed more than 1.3 billion transactions worth over $1.5 trillion in 2022/23, up from more than a billion worth over $1 trillion the year before. Yet the NPP still accounts for only around a quarter of account-to-account payments by number, and about a third of credit transfers. Most account-to-account value still moves over the legacy direct entry system, whose volumes have stayed broadly flat rather than collapsing, and very few direct debits have migrated at all.

PayID has helped, with registrations passing 11 million, but most NPP payments are still addressed to a BSB and account number rather than a PayID. The industry has set a target to decommission the Bulk Electronic Clearing System (BECS) by June 2030, with the bulk of those payments expected to move to the NPP. The direction is set; the pace is the open question.

Will the wallet always keep PayTo in second place?

Here is the uncomfortable read for account-to-account optimists. For in-person and increasingly online retail, the digital wallet is winning on utility. It is instant at the point of sale, near-universally accepted, backed by mature dispute and chargeback protections, and it sits one tap away on a device consumers already trust. PayTo, the NPP's direct-debit successor, is the right tool for recurring and variable billing, payroll and account-funded e-commerce, but it is competing against a card experience that keeps getting better, not standing still.

The regulator's own evidence is blunt about this. In its March 2026 risk assessment of decommissioning the Bulk Electronic Clearing System, the RBA concluded that PayTo has yet to demonstrate its maturity as a direct debit replacement. PayTo use did grow through 2025, but that growth came mostly from new payment agreements rather than the migration of existing direct debits, and the vast majority of account-based pull payments in Australia are still made over BECS. The barriers persist: inconsistent bank service levels, fraud-risk concerns, incomplete NPP reachability, and the fact that PayTo today supports only single transfers, with a bulk initiation capability still under design.

The system that PayTo was built to replace is, for now, barely migrating.

Trust and liability are the deeper unfinished business, and this is the crux. A PayTo dispute is not a card chargeback; it is a mandate claim under the NPP rules, where reversal is not automatic and, because every payment sits behind a standing authorisation, a claim rarely succeeds unless the debit fell outside the agreed terms. Real-time, account-to-account payments also shift risk onto the payer in a way card protections do not, and the allocation of loss for mistaken payments and for authorised scams across A2A is still being worked through. Confirmation of Payee, which checks the payee name before a transfer completes, has begun rolling out across the major banks with a target of covering more than 95 per cent of personal accounts, and it matters precisely because it starts to close that gap.

Until liability, dispute resolution and resilience feel as settled to a payer as a card chargeback does, PayID and PayTo will keep running second or third for everyday retail, however strong the policy tailwind behind them. Resolving the liability framework is arguably the single most important unlock for the BECS-to-NPP migration the whole reform agenda depends on.

What it means, player by player

Banks and issuers face compressed card economics. From 1 October 2026 surcharging on the designated networks ends and interchange caps fall, with issuer interchange revenue expected to drop by around $660 million a year. The defensive instinct is to protect card margin; the smarter move is to make A2A and PayTo genuinely usable, so the migration the regulator wants becomes a business they own rather than a threat they absorb.

Card networks and wallet providers gain in the near term, because repriced cards on a device remain the default way Australians pay. But the review puts mobile wallets, three-party schemes and the fees inside the wallet stack squarely in scope, so today's advantage comes with tomorrow's scrutiny.

Acquirers and PSPs carry new transparency duties, including published merchant fees and clearer statements, which will expose fat margins. The same providers stand to win by helping merchants adopt least-cost routing, which large acquirers had enabled for around 80 per cent of in-person merchants and 95 per cent of online merchants by mid-2025, and by offering credible account-to-account acceptance.

Fintechs and BNPL providers get a clearer perimeter. Buy now pay later, worth roughly $19 billion a year and used by about one in three Australians, is now regulated as credit, and wallets and platforms are next in line. Clarity is the price of legitimacy, and for serious players it is worth paying.

Who benefits

Merchants get lower acceptance costs and, for the first time, the published data to shop around. Consumers get cleaner pricing without surcharge confusion, more ways to pay, and stronger fraud and scam protections as the review turns to cryptography and security. The wider industry gets a more contestable field, where capital flows to genuine innovation rather than to regulatory arbitrage.

The window is short

This is not a spectator sport. Submissions close on 7 August 2026, and the priorities the RBA sets by year end will shape payment economics into the 2030s. Whether you are protecting a card portfolio, repricing an acquiring book, rethinking acceptance, or building the account-to-account proposition that finally earns consumer trust, the time to model the post-surcharging, lower-interchange, wallet-led world is now, not after the rules land.

At Artipi we help businesses and banks navigate exactly this kind of inflection, from payments strategy and channel optimisation through to real-time payments adoption, supplier selection and the change management that makes it stick. If the review has you weighing what it means for your economics, your roadmap or your submission, that is a conversation worth having while the window is open.

Figures cited are drawn from the Reserve Bank of Australia's Payments System Board annual reports, retail payments statistics and the Review of Merchant Card Payment Costs and Surcharging Conclusions Paper. The Review of Payments System Regulation Issues Paper and submission details are available on the RBA website.