On 16 April 2020, the FCA updated its web page on COVID-19 by adding a section on cross-border payments regulation. In this new section the FCA refers to a European Commission statement on 9 April 2020 reminding payment service providers of the forthcoming application date of 19 April 2020 for currency conversion transparency requirements. The Commission recognises that applying these requirements in the current circumstances linked to the COVID-19 pandemic may pose some challenges and understands that Member State national competent authorities may consider it necessary to enforce the new rules in a flexible manner.

The FCA states that it expects firms to comply with the requirements where they can, and if not, to implement these obligations as soon as possible. However, the FCA will take a reasonable approach towards enforcement of the implementation of the new rules in light of the need to preserve the stability and continuity of online payment services. That may mean assessing the immediate need to meet the new transparency obligations against the risk of introducing non-essential risk or a significant reduction in a firm’s capacity to deliver frontline services to customers in the present circumstances.