2026 is set to be another dynamic year in payments. Join our Glenbrook partners as they discuss their perspectives on industry trends and what they’ll be keeping an eye on this year, including:

• Agentic Commerce
• Tokenization
• Stablecoins
• Fast Payments
• Cross-Border Payments
• Subscription and Recurring Payments
• Card Interchange and Surcharging
• Regulation and Banking Trends
• Risk and Fraud

 

 

 

 

Bryan Derman: Hi everyone. This is Brian Derman, a partner at Glenbrook and your host for this episode of Payments on Fire. Happy New Year to everybody out there in payments universe. We’re back to kick off the new year with one of our Fanning the Flame segments, featuring all the partners at Glenbrook. And as is common at this time of year, we want to share some thoughts and predictions on what the hot topics will be in payments this year. Quick spoiler, alert out there, if you thought things might slow down a bit this year, all we can say is better luck next year. We exited 2025 with a lot of major issues pending, and they’re continuing to percolate at different rates here in January.

So to kick things off, let’s just jump in and deal with the two big elephants in the room right away. Agentic commerce and stablecoins emerged as the industry’s mega trends roundabout last spring, and they’ve only gained momentum since then. So let’s cover those first. Drew, talk to us about your emerging perspectives on agentic commerce.

Drew Edmond: Yeah, absolutely. So I think agentic commerce was a huge topic, obviously, last year and going into 2026, I don’t think that’s going to slow down. There are so many different participants in the ecosystem that again, want to kind of assert their leadership and their thought leadership in the space and continue to develop the building blocks and the elements of the ecosystem that need to exist for agentic payments to actually really take off. We’re not there yet at all.

My general prediction for just the overall concept of a agentic commerce, agentic payments is that agentic payments itself, like an actual agent making a payment, won’t be a meaningful channel for B2C merchants this year.

That doesn’t mean it’s not going to happen next year or in the coming years and continue to grow as a potential interesting channel for merchants that serve consumers. But right now, the focus, I think, is a lot more on product discovery and merchants thinking about what they need to do to make their products more accessible to chatbots, more easily understood so that they can even be selected and shown in front of consumers when they are starting to use it for product discovery.

Because that is really the use case that is being used today. We know that 20%, a little bit less than 20% of chatbot users use it weekly, on a weekly basis, and also know that 20% of orders that happened during cyber week last year, at the end of the year, touched an agent. That doesn’t mean the payment was touched, but the order process, the discoverability of the product involved in an agent at that point.

We also see some rumors around things like, Oh, is Open AI going to acquire Pinterest, right? So who knows if that’s true, but even that concept alone is, we know that the commerce element of using chatbots and of AI is going to be a really critical component going forward. And it’s going to continue to kind of expand how it’s being used and what that looks like to consumers from a user interface perspective. If you compare, right, going on Chat GPT, very text heavy interface versus Pinterest, which is basically all images, right?

So I think Agentic payments still has a really long ways to go. A lot of people are working on it. Folks like Stripe with their Agentic Commerce Suite and things like that, making it easier for merchants to make their product set more accessible, more available, easier to use within the world of agentic payments. That’s all going to continue to evolve and merchants will start using it.

Merchants are already using, kind of implementing it and enabling it and things like that. But right now it takes a lot of work to go from zero to agentic payments when you’re a merchant. So I think initial focus this year continue on the product discovery side. Then as things start to catch up, maybe towards the end of the year, but definitely into the following year, we’ll see more about agentic payments.

Bryan Derman: Okay. Simon. In spite of Drew’s dower predictions. I know, I know you’ve been thinking about the payment side of agentic, so give us your take there.

Simon Skinner: Yeah, sure. As we think about agentic commerce and the various protocols and frameworks that are being announced to try and support standardization, although I think we’re a long way from that, I think we’re at a point now where we’ve got several kind of competing models out there.

But anyway, I thought I’d use that as a segue to one of our favorite topics, tokenization. Regular listeners will know, we just can’t stop talking about tokenization. And card networks and probably Mastercard in particular have been pretty vocal stating their ambitions to remove manual PAN entry and replace it with network tokens for all kind of e-commerce online transactions.

And obviously that has sort of merits in its own right. But I think when we look at the Visa Intelligent Commerce and Mastercard’s Agent Pay protocols supporting agentic commerce, tokenization is going to become a core enabler, prerequisite if you will, to support full agentic commerce or payments in agentic commerce.

And so I think we’re going to see, depending on the speed of adoption of full agentic payments, greater proliferation and growth of token issuance and usage linked to that overarching trend.

Bryan Derman: Yeah, fair enough. It’s certainly being worked hard, even if it doesn’t become fully ripe this year. It feels like something’s going to happen. I’ll just pile on a little bit because all the attention, as Drew said, has been on C2B commerce, but it’s our discipline at Glenbrook to think of the world in terms of use cases and what we’ve always called our domains of payments.

We need to look at how agentic commerce will play out across those domains. And I harbor a little theory that the B2B side could become interesting here. It’s a part of the business where there’s already a lot of robotic automation in play, has been for a while, but I think the advent of LLMs and Gen AI bring a new dimension to that in terms of the ability to parse freeform data, which has always been the challenge in B2B.

And invoices and remittance advices and purchase orders are not highly standardized and so the ability for a machine to interpret those has always been limited. LLMs change that picture a little bit, and I think we could see a new wave of automation across supply chains and AR and AP kinds of processes. So that’s a space I’m watching this year.

Let’s go deal with the other elephant, stablecoins. Russ, you’ve been watching this one closely, done several podcasts on this one already. what’s your view coming into the new year?

Russ Jones: Well, we’re not talking about elephants in the room with stablecoins. We’re talking about horses that are at a full gallop. There’s a lot going on in the world of stablecoins, almost as stampede you could say, lot more than a gallop. Looking back at 2025, lots of smoke, not clear that we’re seeing the fire yet, but tons of smoke.

We had the GENIUS Act passed in the US market, which has really put a regulatory stake in the ground around how stablecoins should work in the US. We’ve seen explosive year over year transaction growth in stablecoins, tempered though by the emerging realization that only 20% of those transactions are sort of economic transactions. The rest are more back office transactions, if you will.

We’ve seen tons of infrastructure announcements, Stripe, Worldpay, Visa, basically every payments provider has a stablecoin strategy today. And if they don’t, they’re working on one. We’re moving way past the point where end users might say, my provider doesn’t support this yet.

And we’ve seen a lot of new, maybe in a troubling way, we’ve seen a lot of companies decide that they want their own stablecoin. So Western Union, Fiserv, more recently, Sony have all announced their own initiatives for their own branded stablecoins. It begs the question we ask a lot about, how many of these stablecoins do we need?

So against that backdrop, when I look forward to 2026, my big question is when are we going to see the real use cases? Most stablecoin use today is sort of as a neutral medium between trades in and out of cryptocurrency.

And yeah, you can do real stuff with stablecoins, but in a major way, it really hasn’t gone mainstream yet, if you will. So, I got my eyes certainly on if it will, and where it will. There’s sort of an emerging consensus that the use cases that matter are going to be cross border in nature, not so much domestic use cases.

Bryan Derman: Totally agree there.

Russ Jones: And it’ll be interesting to see, I mentioned Sony with their own stablecoin. It’ll be interesting to see what happens inside of the ecosystems. I’m thinking that the Sony coin actually might be pretty interesting because they have so many different business units and they have a lot of velocity inside their ecosystem. They have opportunities to unify payments in, payments out, as well as unify loyalty and rewards and prepaid cards. They haven’t been explicit yet on what they’re going to do, but you can imagine that there’s a ton of opportunities inside of the big ecosystems.

Bryan Derman: I don’t know whether to think about that as a private label sort of a currency or how they will use it.

Russ Jones: Well, they’re all sort of private label currencies to some extent. And what I was talking about, there’s so many of these stablecoins emerging, I forgot. I left the stablecoin of Wyoming off the list, which for some reason feels like it needs to have its own stablecoin at a state government level.

It is really where the use case is going to emerge and, we’ll be watching that very closely.

Bryan Derman: So Simon, you’re one of the recovering bankers here at Glenbrook, and you, you’ve been thinking about an emerging alternative. So talk to us about tokenized deposits.

Simon Skinner: As we are thinking about the digital crypto world, thought I’d make a worthy mention of another component that’s perhaps been the sort of lesser known cousin of stablecoins. So yeah, tokenized bank deposits. Blockchain based dollars directly linked as a digital claim on existing funds.

I think it’ll be interesting to kind of see how they evolve over 2026. They’re, as a concept, been around for a while. They are gaining a bit more visibility. Origins have been on private blockchains and limited to kind of walled garden of existing bank clients.

But we are starting to see banks enabling these tokenized deposits on public blockchains. And so, given the nature of these kind of interest bearing digital tokens in a similar way to stablecoins, it’d be interesting to see kind of where they gain real traction and for what use cases in the year or years ahead.

Will that usage break out from institutional clients where it sort of has been to date and will usage be in lieu of stablecoins or as an enabler to stablecoins?

Russ Jones: As an alternative to stablecoins.

Simon Skinner: Yeah. Right.

Russ Jones: Yeah. Really, when I look out on the horizon here, stablecoins have a pretty wide open playing field right now. But there’s really four big trends in the marketplace that kind of work against stablecoins to some degree. One, we have the world of international wires and Swift.

Those wires are getting faster all the time, kind of taking away the edge that stablecoins like to think they have there. Swift is now claiming that 75% of international wires arrive at the recipient’s bank in 10 minutes. And cost has come down dramatically for corporations. You got that sort of working against stablecoins.

You have fast payment systems starting to interconnect around the world. What’s wrong with point to point fiat money moving instantly? That’s an interesting thing. And then banks exploring tokenized deposits, maybe that undercuts the B2B use case that stablecoins might have otherwise.

And then our old friend, Central Bank Digital Currency, still alive and kicking in a lot of countries around the world. And that sort of trumps stablecoin initiatives in those markets, if there’s actually digital currency that’s the fiat currency of the country.

Bryan Derman: Yeah, certainly for domestic use cases.

Russ Jones: Yeah, for sure.

Bryan Derman: Seems superior. Obviously, the big distinction here is that stablecoins under the GENIUS Act are backed one for one by high quality short duration securities, whereas bank deposits are backed fractionally, that 10% here in the US. So the economic leverage is certainly on the side of a tokenized deposit if the utility is equal or similar. Definitely something to watch.

Okay. So, if stablecoins are the new, new thing then maybe instant payments qualifies, instant payments over traditional rails, as Russ just talked about, maybe that’s sort of the old new thing, but still pretty new.

Activity is growing here in the US, happening sort of quietly, but not so quiet around the rest of the world. Right, Joanna, this is your bailiwick and I know you’re watching a lot of systems around the world. Tell us what you see coming.

Joanna Wisniecka: That’s right, Bryan. What’s old to some is new and exciting to others. I spend most of my time thinking about emerging and developing economies in particular, and much of it on how well-designed payments systems, in particular, instant payment systems enable financial inclusion.

And I can say that instant or fast payment systems, same thing, have been and will continue to be hot. In 2025, we saw a number of these systems being implemented globally in more and more countries, certainly paying quite a bit of attention to the African continent. We saw them pop up in Liberia, Gambia, Rwanda, as well as a couple of regional systems, on the continent. That’s going to continue to accelerate, continue and accelerate.

And it’s not just the African continent. I think the biggest announcement of an instant payment system coming is Bangladesh. If you think of Bangladesh, size of the population, that’s big one. May not be quite implemented in 2026, but it’s on the way.

I’ll say that these implementations are happening fast and faster. In the case of Liberia, for example, it was implemented in a matter of weeks. We’re not talking about years here, not months, in a matter of weeks. This was becoming more standardized, at least at the most basic level of P2P use case.

And speaking of use cases, I think that’s a, a theme we’ve got going here in this conversation. For the IPS that are already in place, I expect to see more continued growth in that person to business use case, in particular the merchant payments use case. Again, many of the systems start with P2P, and then over time that use case has seen growth. That is definitely the case in UPI and Pix, and in fact, it’s now the case that most of the volume in both of those systems, UPI and Pix is coming from P2B.

So in Pix for example, it surpassed P2P in just September. Most of that is for kind of everyday purchases. And also why is that? Constant stream of improvements, right? We’ve seen national QR codes. We’ve seen innovations like voice confirmations to help address fraud better, complaint or resolution mechanisms, recurring payments.

That’s definitely the case in Pix. So P2B is going to be the story, I think, in instant payment systems in 2026.

Bryan Derman: Really interesting. Simon, you’ve been thinking about these systems and working on them as well. What’s your take?

Simon Skinner: I think I just have an overarching observation that as perhaps more and more instant payment systems are implemented around the world, almost like the definition of what constitutes an instant payment system is evolving. I don’t mean in terms of like the real time nature of, and the irrevocable nature of, the payment or settlement. I mean in terms of like what do you class as the core components and aspects of the system.

So if we think about some of the forward monitoring and confirmation of payee capabilities that a few years ago were sort of considered optional overlay services, I think what we’re now seeing is as countries and the various agencies address the unwanted growth of things like an authorized push payment fraud and scams, so actually those components are now core.

You can’t really put forward a kind of instant payment system without considering those broader systemwide benefits, and so you almost got a kind of an expansion of what is the core of an instant payment system.

Bryan Derman: It’s a real mark of maturation, isn’t it, for these systems, right? They’re so mainstream that people are using them fraudulently now. Right? Congratulations. Welcome to the payments world.

Simon Skinner: Yep. Yep.

Joanna Wisniecka: Great point, Simon. We’re also seeing the systems implement, not just kind of your basic foundational monitoring, right, fraud monitoring, but also providing functionalities for end users at the payments system level, and requiring their participants to provide functionalities to end users, to make requests for funds, refunds in case of fraud, much easier.

So there’s this user experience element to that too, that the schemes themselves are paying attention to and implementing.

Simon Skinner: Russ kind of briefly mentioned this earlier, but another sort of trend that we’re closely monitoring is the interoperability and interconnection of those instant payment systems to support cross-border activity. And there’ve been examples of this in a sort of bilateral way. So, one system in one country connecting to one system in another for a few years. I think. Singapore’s Pay Now and Thailand’s Prompt Pay Connection is a sort of good example of that.

But as we look forward into the year ahead, and hopefully it’s the year ahead, I think we’re kind of interested to see whether BIS’s Project Nexus, which is putting together a single platform that can link multiple instant payment systems into like one interoperable network, actually starts to take, well, not take shape, it’s been taking shape over the years, but actually gets to market with a real live implementation.

Last year the Nexus Global Payments organization was kind of formed to move the activities forward on a commercial basis. And so I think that we’re looking eagerly into the year ahead to see whether we see the first real live implementation of that.

Joanna Wisniecka: You mentioned the number of efforts that have been in place, BIS taking kind of a policy perspective on cross-border payments and improving challenges in this space. That G20 initiative focused on improvements to cross-border payments has been going on for some time now.

What I think is interesting, as of recently, a couple of months ago, they announced that these targets, ambitious targets that they set for themselves on addressing some of the challenges like affordability, speed, efficiency, transparency of cross-border payments, that they’re going to miss the mark on those targets that they’ve set for themselves.

In particular, I think Russ mentioned, increase in speed of cross-border payments. They acknowledge that that is one of the maybe successes. But what is not a success is the reduction of cost in cross-border payments, in particular in the retail remittances space. Those remain quite high. So we’ll be paying attention to what other tricks can they pull out of the bag to support reduction in cost?

Again, my kind of lens of fast payment systems, I’m thinking about, well, how can the design of the systems help to support that? Some of the things that we’re seeing are an example is this FX marketplaces that these interlinked systems or regional systems are implementing with the goal of increasing competition for FX and reducing costs. So maybe more of those types of kind of at the center solutions.

From an instant payments perspective, it will take a lot more than just system design regulations, policy a lot more to solve this problem, which they’ve been at for a long time.

Chris Uriarte: I think this speaks to what you and I were chatting about the other day, Joanna, in that you probably have the fintechs and the global money movement companies cheering a little bit at this and saying, Hey, you guys think this is so easy. Guess what? It’s really not. So it doesn’t seem like the likes of the Wises, Xooms, or even Western Union are going away anytime soon.

Joanna Wisniecka: Yeah, very true.

Bryan Derman: I read somewhere that cross-border was hard. Maybe that was a Glenbrook article or something that said that.

Anyways, Drew, I’ll throw it back to you because we’re never complete until we’ve talked about subscriptions and recurring payments, right? What’s going on in that world?

Drew Edmond: Something that was interesting last year that happened was there was all this hubbub, talk about the FTC and their click to cancel rule, where the rules would be for subscription and recurring merchants that you needed to make it easier for subscribers to cancel their subscriptions, kind of in the same channel that they signed up in. Also more rules around what you must do prior to onboarding a customer onto a subscription, kind of in that negative option manner where all of a sudden they have a subscription and maybe they don’t even know about it.

The intent was to make rules that were in the consumer’s favor when it comes to ensuring clarity around the information that was being shared with these consumers, and of course, making it easier for them to cancel. I think we’ve all probably had experiences in our own lives where it was a hair tearing out experience, just trying to figure out where to go to cancel a particular subscription.

That went away. The FTC decided not to enforce that rule at the end of the day. Now the word on the street is that it’s coming back. We’ve got some different consumer groups that are out there, pushing for this to come back. The FTC has been taking comments on it again. They just closed comments a few days ago. I think that’s kind of the area to focus on, primarily in the subscription space, to see where that rule ends up going. Does that end up going live this year? We’ll have to see.

I think another area that kind of continues that trend of pushing control of subscriptions and financial services to the consumer, more and more, seeing financial institutions enabling the ability to manage their subscriptions from bank apps themselves, right? Rather than having to go directly to the merchant that you are working with and having to cancel that subscription or pause that subscription.

Being able to do that from a trusted application like your bank, I think that will continue to grow. There’s definitely differing opinions in the ecosystem about is that the right thing to do? Is that what we want consumers to do? Certainly merchants would prefer if their customers are coming to them to manage their relationship with that merchant.

That being said, we just generally see this trend right, of putting more control in the hands of subscribers to do what they want with that subscription. And in some cases that means managing that somewhere else other than the merchant.

Bryan Derman: Interesting, interesting. On the other hand, we have to always pause for a minute and just admire the way commerce has flowed into that subscription model. Every time I glance at my credit card statement, I’m amazed by the list of recurring statements

Drew Edmond: Absolutely.

Russ Jones: Are you sure amazed is the right word?

Bryan Derman: I don’t know, how did my iPhone become a subscription?

Drew Edmond: I think it, it makes a good point, right? And because that number is so high, the number of subscriptions on a per consumer basis is so high at this point, due to all the different opportunities you have to have a subscription.

To be able to manage your own individual finances on a day-to-day, weekly, monthly basis, a major part of that is managing which subscriptions you still use and that you need to use. And maybe you do need to pause, maybe you do need to cancel it. And so if that means you have to go to 20, 30 different places rather than just go to a centralized place, I can see why there would be a drive to centralize this where you already are already going to look at your financial services right.

I could see it from both angles from the bank saying, yeah, I want to make this available to my customers because it’s in their best interest. I’m trying to help them out. Merchants, of course, are saying, well, it’s in my best interest to manage the relationship directly with my customers. So there’s always going to be a bit of tension there. So, we’ll see how that progresses.

Russ Jones: There’s a reason they call it the subscription economy, you know?

Bryan Derman: There it is.

Drew Edmond: Yes, yes. We’re in it. We’re living it.

Chris Uriarte: I’m still really thrilled that I canceled my cable subscription just to replace it with 14 different streaming services.

Drew Edmond: Exactly.

Bryan Derman: Why pay one subscription when you can pay 10.

Drew Edmond: Imagine if you could bundle all those into one place.

Bryan Derman: Amazing. Yeah. Hey Chris, I don’t know if listeners out there would be aware of this, but this is the year when Glenbrook is going to turn 25 years old. And we’ll have more to say about that on the podcast as we go through the year.

But if there’s one topic we’ve been talking about every year for 25 years, it’s probably card interchange. So, as we boldly move into year 26 of Glenbrook, what are we going to be talking about in the interchange world?

Chris Uriarte: Well, I mean, almost 25 years old as well is what I’m going to hit on, which is this Visa and Mastercard merchant settlement which made big headlines this year. We did a Payments on Fire episode on this and spoke a lot about this toward the end of the year. It was finally announced that there was a new settlement that was being proposed between Visa, Mastercard, and the merchant groups.

And the roots of this case really goes back to early 2005. So we’ve already been working on this for over 20 years. And here we are with a new proposal and, quite complex, I mean, these settlements are quite complex of course, but as we talked about in our Payments on Fire episode last year in 2025, there were a couple key dimensions around this settlement.

A number of things that had to do with selective card acceptance, some that had to do with surcharging and discounting, and the flexibility that merchants had on that. But of course interchange was a key topic there. And some sort of complex proposals around interchange rate reductions for a short period of time, looking at sort of a weighted average interchange, reduction of about 10 basis points, something along those lines, but it gets quite complex. I don’t mean to oversimplify it here, and of course you could do a lot of reading about it, or you could go back to our podcast episode.

But I think the big question, if we’re looking at 2026 predictions, is whether any of this is going to stick at all because we have seen these proposed settlements occur now over the course of the last couple decades, only to be struck down. And this is why we are where we are today. The previous version of this was struck down and there are a lot of merchant groups that are just not happy with this settlement, that’s really saying that what is being proposed is just not enough from an interchange savings perspective.

Merchants continuing to stress the fact that interchange is only one component of what merchants pay on a per transaction basis, and that overall, the total cost of payments, when you look at interchange scheme fees and everything else that gets thrown into that, has been increasing year over year. So merchants as a whole have not been very, very happy about what’s been proposed here. So it’ll be interesting to see whether the courts come back and they say that this will stick, or whether we have to go back to the drawing board and do something a little different.

Bryan Derman: Yeah. And if I remember correctly, a small company called Walmart has already-

Chris Uriarte: Yeah.

Bryan Derman: -opted out of the settlement, which may or may not influence the judge here, but seemed to be part of the undoing the last time around.

I have to say, the one piece of that that really caught my eye was this surcharging element and kind of the what to me was a new openness on the part of the card networks to accepting surcharging with a reduced level of enforcement and with an ability to apply differential surcharges to different grades of products. Has to be consistent across issuers and practices have to be similar across networks, but different kinds of cards can be surcharged at different levels. I think that creates an interesting dynamic.

One thing that’s very clear is consumers don’t love surcharges. It’s never a welcome development when you get to the cash register or whatever point of sale it is.

Russ Jones: Is don’t love a synonym for hate?

Bryan Derman: Yeah. Hate and maybe some stronger words too.

Chris Uriarte: It is interesting that, they did give a little bit on that. It only adds to the patchwork of confusion and complexity around surcharging in the United States. I think anyone who’s dug into this knows that you have federal regulations around surcharging. You have state regulations around surcharging. You have card network regulations and rules around surcharging. Different surcharging limits and thresholds based on a combination of those. You can surcharge credit, but you can’t surcharge debit. It is a really, really complex, it’s a mine field of regulations when you go into surcharging for sure.

Bryan Derman: And some of them are even followed, right?

Chris Uriarte: Yeah.

Bryan Derman: In a world where there are people out there paying up to 900 bucks a year in annual fees for a card and then you’re going to pay a surcharge at the point of sale, I don’t know what the limit of consumer tolerance is across these things, but I sense it’s going to have to get worked out and probably disclosed a lot better.

And that’s my pet peeve, is you almost don’t know when it’s going to happen to you because the disclosure on average is terrible. Not that there aren’t some merchants doing the right thing and all of that, but maybe it’s just the ones that I go to that are not doing a very good job of it.

That’s a very US-centric view. Simon, the global view is also in motion, though.

Simon Skinner: You talk about kind of consumers not loving, or hating maybe, the kind of surcharging dynamic. I think if you look kind of more broadly, it’s not just consumers that are sort of taking that view, but also, regulators taking a bit of a dim view of surcharging practices.

So, Reserve Bank of Australia is in the process of finalizing a ban on card surcharging across EFTPOS, Visa, Mastercard. And of course you look at other jurisdictions like the UK and EU have already prohibited card surcharging in most cases. And so you do have this mix of markets that are allowing surcharging practices and those that are essentially trying to stamp it out for consumer interest. So I think it’d be interesting as we move forward to see whether other jurisdictions follow the stamp it out approach or the kind of allow it for commercial reasons.

Chris Uriarte: I think the interchange conversation also comes into play in Australia as well, because in addition to the surcharging ban, the regulator has also said that they’re going to reduce the already fairly low regulated interchange caps in Australia.

So you have a very, very heavy-handed regulator in Australia that’s really working on behalf of consumers and merchants down there.

Bryan Derman: You have to salute the RBA for consistency, don’t you? They were the first to regulate interchange. Why not be the first to regulate surcharging too? They’re always at the forefront of this stuff, so good on them as the Aussies would say.

All that said, I’m going to boldly predict that unlike the past few years, nobody is going to declare 2026 the year of the regulator, as we have for the past couple of years. The trend feels like it’s going the other way, particularly here in the US. And one of the trends I’m watching here is the return of de novo banking, de novo chartering of new banks, which has barely happened for 5 or 10 years here is suddenly, got underway in 2025 and is picking up steam in 2026.

And we’re seeing fintechs and other non-banks often going for different sorts of limited purpose charters. The Industrial Loan Corp is back as a bank charter, National Trust charters are a new thing. We’re seeing some fintechs go for, and even a few going for full on national banking charters. And the administration here has really shown an openness to that and kind of bringing the fintechs into the formal side of things.

So you wonder if that will lead to in some ways the US looking a lot more like the rest of the world where e-money licenses and different sort of lightweight charters, payment institutions sort of chartering have become pretty common and maybe a lessening of dependence on the somewhat odd sponsor banking model that we’ve had here in the US where fintechs team up with banks in what is sometimes an uneasy relationship to bring modern financial services to consumers and businesses. So that’s one thing I’m watching this year.

If things are loosening up a little bit here, that’s nice, but regulation never sleeps in Europe, does it?

Chris Uriarte: Yeah, for sure. So I think the big thing that’s been on folks minds in regards to European regulation is PSD3 and the PSR, the Payment Systems Regulation. The various bodies have been working through that over the course of the last, I’d say three to four years now. So this is the evolution of the previous PSD2, Payment System Directive Version Two.

And as we’ve talked about on this podcast and number of other forms is we see PSD3 as more of a general evolution of payments regulation in Europe, not necessarily revolution per se. I mean, PSD2 was a bit of a shock to the system to sort of everybody throughout the value chain and introduce some of the beloved concepts that Europeans are used to today, like strong customer authentication, the use of 3D-Secure consistently at checkout, and things along those lines.

PSD3 builds on top of that very strong regulatory framework that’s already been in place and has been implemented and tweaks it, tunes it, has tried to respond to some of the concerns that have been raised over the course of the last decade or so. So a little bit less of a shock to the system to everybody throughout the value chain.

These things take time. It’s not officially approved yet. And like everything else from an EU regulatory perspective, after initial approval, it does go into a state where it needs to be implemented at a member state level, which does take yet almost another years plus time. So we should be seeing the approval sometime soon. Not sure exactly when. But it’s still going to be quite a bit of time before that requires some level of implementation amongst, member states and then, eventually trickles down to merchants, PSPs, banks, et cetera.

Bryan Derman: Definitely one to watch in the coming year. Just before we wrap, you can never talk about payments without talking about risk and fraud. So Chris, without making us all want to stuff dollar bills into the mattress. Tell us what you think lies ahead for fraud and other financial crime in this new year.

Chris Uriarte: Well, you know, of course the word fraud is used very, very broadly. But if we look at it strictly from a payments perspective, and specifically if we start to look at cards, for example, there’s actually some good news is, we’ve gotten indicators from a number of different studies, number of different sources, like the annual Nielsen fraud report that shows that global card fraud is again for another year in a row, ticking down a few basis points. So that is a good thing.

But we do know that we are in this constant state of change and constant state of innovation. And as we’ve talked about elephant number one in the room to start our discussion today, big question is how does agentic commerce play into the overall picture of fraud, how is that going to impact fraud from a merchant perspective, how is that going to impact disputes? What do merchants have to consider from a tools, technologies, process perspective?

And how do the rules at the card network level need to change? How do they need to adapt to a scenario where a consumer charges something back because an agent decided to buy the wrong color pair of shoes in the middle of the night for them. A lot of questions around this that we’ll have to address in the coming year as agentic starts to proliferate and become more and more mature.

I’d also say what’s going hand in hand with the agentic discussion is the discussion of Visa’s new monitoring program, which is called VAMP that went live last year. So we’ve starting just now to see what the impact of VAMP is and VAMP takes into consideration disputes as much as it does true fraud, right?

Bryan Derman: Define it a little bit for folks who don’t live, all the time on the merchant side. We’re talking here about Visa rules in this case.

Chris Uriarte: Yeah, absolutely. We’re talking about the Visa Acquirer Monitoring Program and historically Visa had looked at fraud thresholds at merchants separately when looking at true fraud rates versus dispute rates. Those were different programs and they were handled differently. Now, what Visa’s done is they’ve kind of put those two metrics together and they’ve said, we’re going to collectively look at your dispute rates and your fraud rates together.

So if you were a merchant that had lots and lots of disputes that you were resolving, that never really turned into chargebacks historically, maybe you were never actually put into any of those programs. But now what some merchants are finding is that when you put those two metrics together, all of a sudden they’re exceeding the thresholds of the VAMP program.

So talk about shocks to the system, as we were talking about with PSD2, this has been a shock to the system to a lot of merchants. And it was a major point of discussion for 2025, will continue to be a point of discussion for 2026. And in the context of agentic commerce, where perhaps you have all these agents and robots running around doing things on behalf of consumers in a not yet quite mature environment, does this mean that there’s going to be a lot more disputes? And does this mean that this program is going to be much, much more, potent and relevant when it comes to monitoring these thresholds on the merchant level?

Bryan Derman: Yeah, definitely one to watch. And I know a big concern to a lot of our merchant clients, so please keep an eye on that and let’s report back.

Okay. Wow, that’s a pretty good start to the year. We’ve got a lot to monitor here. A lot of issues to watch that we know of, probably a few others that haven’t even hit our radar yet. We will get some surprises as we move through the year, some stuff that none of us is thinking about today.

So, thanks for giving us that preview and we will keep watching all of these things. So payments people, strap yourselves in, I think we are in for another wild ride. Very excited to be on the journey with you. Tune back in and we will keep you posted. Take care, keep the world safe for payments and have a great year. That’s Glenbrook out.