As part of our work on cross-border interchange fees remedies, the Payment Systems Regulator (PSR) has appointed IFF Research to run a survey of UK merchants to gather data on their costs for processing online payments from the European Economic Area when using cards or alternative payment methods.
We will use the results of the survey, together with other data, to undertake a Merchant Indifference Test (MIT), which will form part of our assessment of the appropriate level for cross-border interchange fees for these types of transactions.
We had previously published a version of the draft questionnaire for comment as part of our October 2025 consultation on methodology for developing a price cap remedy.
Since then, we and IFF Research have updated the questionnaire based on responses from parties to that consultation, additional information we have gathered, and IFF’s expert opinion.
While we have not made a final decision on which comparators we will ultimately use in the MIT analysis, we have only included questions on alternative payment methods that could plausibly be used in the MIT analysis. Having considered submissions in response to our October 2025 consultation, we have decided that the merchant survey should collect information on the following alternative payment methods to cards:
- Payment methods based on SEPA bank transfers (including iDEAL, Przelewy24, Blik, Bancontact, Sofort/Klarna Pay in full, Trustly and SEPA direct debit, amongst others)
- PayPal
- Klarna’s ‘Pay in 30 days’ product.
We have decided not to collect information on American Express. As we explained in our consultation document, competition between American Express and four-party schemes implies that its merchant fees are influenced by Mastercard and Visa’s MIFs. We consider that it is not possible to remove the impact of Mastercard/Visa fees by correcting American Express’s merchant fees in a way that would allow for a sensible application of the MIT.
We now welcome final comments on the draft questionnaire to be used in the proposed survey.
The questionnaire may be revised ahead of fieldwork, to reflect comments received and/or our own development of the questions and the responses from any pilot survey.
The deadline for comment on the draft questionnaire is 5pm on Thursday 5 March 2026. All comments should be addressed to [email protected]