This consultation closed on 17 July 2025, and we have published our response.
Why are we consulting?
A competitive tender as required by Specific Direction 4 (SD4) and SD4a may not now be an effective way of reducing the risks associated with the lack of effective competition for the supply of LINK’s central infrastructure.
We are mindful however of the risks associated with the removal of a requirement to competitively procure and the strengthened position that creates for a supplier of a critical payment central infrastructure.
Given the current market, we consider that this is best addressed through active regulatory oversight of the supplier to ensure that risks associated with a monopoly position are mitigated. We have spoken to a range of stakeholders about our assessment. Based on the impact of decreased cash withdrawals leading to reduced scheme revenues, we are considering revoking the SD4 requirement.
We consider that SD4 is now less likely to be a proportionate and effective requirement, but we want to ensure that all interested parties have an opportunity to comment before we take a final decision. We are particularly interested in views on how the proactive supervision of LINK and its chosen infrastructure supplier could mitigate against the potential knock-on effects and the risks that the removal of SD4 could create on competition, innovation and end-user outcomes.
What is in the document?
The document sets out our views on the potential revocation of SD4 and costs and benefits considerations.
Who should read this document?
This document is relevant to the payments industry and particularly those interested in the operation of the LINK system.