The BRC Finance Community Horizon Scan event brought members together for an interactive, forward-looking exploration of the regulatory, commercial, and technological trends shaping the future of retail finance.
Sessions included the National Payments Vision and its shift from strategic reform to 2026 onwards delivery, an engaging commercial workshop on AI driven, agentic commerce and how innovative payment methods can drive growth, profitability, and customer value for retailers, and a collaborative horizon scanning discussion on upcoming regulatory and financial changes—from mandatory e-invoicing and consumer credit reform to payments modernization, fraud resilience, and digital currencies.
1. RSM Horizon Scanning session
Jacqui Baker, Partner, Head of Consumer Markets, RSM UK
Zoe Morton, Director, RSM UK
Joost Willemsen, Partner
Global VAT Compliance & Reporting
Sarah Waddington, Partner, RSM UK
Consumer Markets and Consumer Sentiment
Speakers discussed trends and changes in consumer behaviour including more careful spending and increased price sensitivity. Monitors show that consumers will still spend where there is clear value.
Consumer finances showed a modest improvement in May, with 49% describing themselves as financially comfortable, up from April. Despite this, confidence remains fragile – only 36% feel optimistic, and most are not expecting meaningful improvement in the near term. Spending remains cautious, particularly on big-ticket items, with very limited intention to increase major purchases. The core theme is value-led spending: consumers are still willing to spend, but only where they see clear justification. Demand is not disappearing, but it is becoming more selective.
Future of Consumer Credit
Credit has become embedded in retail and is continuing to climb: 20% of UK adults have deferred credit in retail and UK has a higher proportion than most countries. Credit drives the consumer journey from the outset and influences affordability.
RMT and FCA is looking for consistency and accountability from those facilitating credit use. From July 2026, BNPL providers need FCA authorisation, with tighter transparency and consumer-protection expectations.
Retailers must have data on usage and drop off of these schemes in order to make clear decisions. It is an expectation that these reforms will result in a drop off of consumers through the journey.
Electronic Invoicing Consultation
E‑invoicing is moving from a future concept to a business-critical requirement, driven by the need to improve tax compliance and data transparency. There is no firm go-live date yet, but the scale of change, especially master data and systems integration, means early movers will be in the strongest position. The direction of travel suggests closer alignment with European models. It is likely that electronic invoicing will become mandatory in the EU over time and the UK is likely to follow in order to standardise with its closest trading partners.
Financial Reporting
Two clocks are ticking. IFRS 18 is having a presentational change for improved P&L comparability, more transparency on management-defined metrics, more structured presentation. Effective from January 2027. Changes to UK GAAP/FRS 102, effective January 2026, are already underway): a performance-obligation model for revenue recognition, and more leases coming onto the balance sheet. For finance teams, early planning and data readiness are essential. Impact will vary, but KPIs, reporting processes and stakeholder communication are all in scope.
Across all topics, a consistent theme emerged. The environment is becoming more complex. Regulation and transparency are increasing. Businesses that invest early in data, systems and insight will be best placed to respond.
RSM helpful resources
- RSM Consumer Outlook - Consumer Outlook 2026 | RSM UK
- Consumer Credit & BNPL - Klarna in a position of strength as BNPL rules tighten
- Financial Reporting - Bridging the GAAP – Insights & UK GAAP: preparing for change
Please contact Jacqui Baker, Partner, Head of Consumer Markets, RSM UK for any thoughts or questions.
2. Payments Forward Plan and Pay by Bank
Jack Wilson, VP Policy and Research, Truelayer
Laura Mountford, Deputy Director, Payments & Fintech Team
The UK government’s Payments Forward Plan, developed from the National Payments Vision, sets out a coordinated three-year roadmap for the UK payments ecosystem. It covers a range of initiatives relevant to retailers from a payments perspective—including payment infrastructure, open banking, digital assets, consumer protections and regulatory reform—while providing greater clarity on the direction and timing of future changes.
Pay by Bank has continued to gain momentum in the UK as an alternative payment method that enables consumers to pay directly from their bank account using Open Banking technology. Retailers are increasingly exploring its potential due to benefits such as lower acceptance costs than cards, instant account-to-account payments, and reduced reliance on traditional card schemes. While adoption is still at an earlier stage than card payments, industry and government initiatives are focused on improving consumer protections, user experience and commercial frameworks to support broader merchant and consumer uptake.
The session highlighted the Government’s renewed focus on payments reform through the National Payments Plan, which aims to bring greater clarity and coordination to what has previously been a crowded and fragmented reform landscape. From a retail perspective, there is a strong emphasis on the growth of open banking, particularly “pay by bank,” as a key opportunity to increase competition and deliver better outcomes for consumers. Alongside this, the Government is progressing reforms to core payments infrastructure, including Faster Payments and BACS, to ensure systems are fit for purpose and support future innovation. There is also a concerted effort to improve coordination between the Treasury and regulators, ensuring reforms are better sequenced and aligned.
Looking ahead, the Government is expected to set out plans to modernise payment services legislation over the next year, as well as its position on emerging areas such as tokenised payments. The forthcoming Financial Services Bill will formalise the merger of the Payment Systems Regulator (PSR) into the FCA, although in practice the two bodies are already working closely together.
Jack at Truelayer emphasised the potential for pay by bank to challenge the current dominance of Visa and Mastercard, which currently cost retailers significant sums in transaction fees. New legislation requiring banks to support pay by bank, without earning interchange fees, could enable substantial cost savings for retailers through a simpler, flat-fee model.
Progress is already being made to make pay by bank a viable competitor to card payments. Industry efforts are focused on achieving a level playing field with card schemes, including enabling recurring payments: an area where progress has historically been limited by regulation. Recent collaboration between fintechs and banks has led to the launch of the UK Payments Initiative, enabling “bank on file” recurring payments for the first time. Early adoption has been encouraging, with major retailers such as Amazon already processing thousands of transactions daily despite minimal promotion, suggesting strong potential for wider uptake.
Please contact Jack Wilson with any thoughts or questions.
3. Agentic commerce
Simon Hunter, Director – Agentic Commerce and Payment Optimisation, Signifyd
The discussion explored the rapid evolution of agentic commerce, highlighting a clear progression from “agent-assisted” models (where AI supports discovery but humans complete purchases) towards more advanced “agent-activated” and ultimately “agent-native” transactions. While AI-enabled product discovery is not entirely new, there has been a notable shift towards purchases increasingly initiated through chatbots, with the longer-term trajectory pointing towards fully autonomous purchasing by AI agents.
For retailers, this trend presents both opportunities and challenges. AI agents could significantly enhance personalisation and streamline the customer journey, for example by building baskets based on inferred consumer preferences or interacting with loyalty programmes to optimise offers. However, merchants are already bearing many of the costs associated with this shift, and the growing role of bots introduces new operational and strategic considerations.
A key concern raised was the evolving risk and liability landscape. As agentic commerce develops, there is likely to be a point at which merchants become responsible for the actions of bots, particularly in cases of error, fraud or misuse. This raises fundamental questions about accountability, specifically who carries the loss when things go wrong, and how responsibility can be evidenced in transactions where no human is directly involved at the point of purchase.
The transition to fully agent-native commerce also challenges existing payments frameworks, which are typically designed around human authentication and interaction. This creates a potential gap in current systems, underlining the need for new approaches to authentication and transaction validation that are suitable for AI-driven purchasing.
Overall, the recommendation for businesses is not to resist or block these developments, but to engage proactively, particularly by exploring how agentic transactions can be securely authenticated and managed. As the technology continues to evolve, establishing clear governance, risk management and trust frameworks will be critical to enabling safe and scalable adoption.
Please contact Simon Hunter, Director – Agentic Commerce and Payment Optimisation, Signifyd with any thoughts or questions.
Slides from the event can be downloaded below.
