Reported development
The Reserve Bank of Australia published its summary of submissions to the Review of Payments System Regulation Issues Paper in October 2026; its news index dates the release to 6 October. The RBA says it received seventy-three written submissions following the June issues paper. It plans to identify regulatory priorities by the end of 2026 and begin further consultation on prioritised issues from mid-2027.
A summary of submissions is not a new rule or a determination that every stakeholder proposal will be adopted. The RBA describes an assessment under its mandate concerning risk, efficiency, competition and financial stability. The following independent analysis considers how merchants can prepare useful operational evidence while that process continues. It does not predict the regulator's decisions or create a new compliance deadline.
Independent analysis: distinguish policy stages
Maintain a simple register of relevant policy developments. Label each item as a consultation, summary, proposed measure, final decision or effective requirement. Include the source, jurisdiction and date checked. This prevents teams from treating a headline about possible reform as permission to change current payment practices. It also helps management see which developments call for monitoring and which require an implementation project.
Assign ownership for interpreting changes before they reach the checkout. Finance may assess pricing consequences, legal advisers may review obligations, and technology teams may need to alter interfaces or reporting. Those activities should follow the actual stage of the measure. A merchant can prepare evidence now without pretending that the final outcome is known. Keep assumptions visible in planning documents and revisit them when the regulator publishes the next formal step.
Independent analysis: make payment costs comparable
A meaningful cost comparison needs a consistent transaction base. Separate domestic and international activity, payment method, channel and currency where the records allow it. Identify fixed charges, variable charges and costs associated with exceptions. An average percentage calculated across an changing mix can be misleading, especially if seasonal visitors or larger business payments alter the basket of transactions between comparison periods.
Prepare a worked example using your own invoices and settlements. Show gross sales, refunds, processing charges and the amount deposited into the business account. Explain any reserve movement separately rather than automatically treating temporarily held money as a processing fee. The purpose is to make commercial effects observable. A regulator or provider can engage more productively with a clearly reconciled example than with an unsupported claim that payments have become expensive.
Independent analysis: document access problems precisely
When a business reports difficulty obtaining payment services, the description should identify what was requested and what response was received. Distinguish an unavailable technical feature from an underwriting refusal, unsupported jurisdiction or incomplete application. Record whether the provider requested further evidence and whether the merchant supplied it. This does not determine whether the decision was justified, but it makes the issue capable of informed review.
For complex business models, prepare a clear explanation of products, customer locations, delivery timing and transaction patterns. Avoid assuming that another business with the same broad industry label has identical risk. A useful record connects the merchant's actual activity with the specific service sought. If commercial negotiations fail, preserve the written terms and unresolved questions. That evidence can support a later comparison without disclosing customer information unnecessarily or relying on recollections of a sales call.
Independent analysis: measure operational friction
Payment efficiency is not captured fully by a headline rate. Record the time required to reconcile settlements, resolve payment failures, obtain refund status and handle customer queries. Where possible, connect manual work with a transaction reference and a repeatable cause. This helps the business distinguish occasional mistakes from a process that consistently creates avoidable cost. It also gives providers concrete issues to investigate.
A practical example might involve a settlement report that combines several stores without usable references. Another might involve customers being charged successfully while orders remain marked unpaid. Describe the frequency, customer effect and staff time involved. Avoid attributing every problem to the payment network when the merchant's integration may contribute. Evidence is stronger when it acknowledges the complete process and identifies what information would be needed to determine responsibility fairly.
Independent analysis: compare switching costs honestly
Changing providers can involve integration work, revised reporting, customer communication and continuing obligations to the previous provider. Prepare a transition budget that includes those items rather than comparing only new transaction rates. For subscription businesses, separately assess stored credentials and billing schedules. For physical merchants, consider terminal deployment, staff training and support coverage. The relevant costs depend on the actual arrangement and should be verified rather than assumed.
Include a period during which both old and new records remain accessible. Refunds and disputes may concern historical transactions after new sales have moved elsewhere. Decide who retains access, how reports are downloaded and which team owns unresolved cases. A provider comparison should explain the exit process as clearly as the onboarding process. This gives management a better basis for decisions and creates useful evidence about practical barriers to changing payment arrangements.
Independent analysis: prepare constructive submissions and questions
If the business participates in a future consultation, organise the response around verifiable examples and clearly stated outcomes. Explain the problem, the affected transactions, the operational consequence and the evidence supporting it. Separate confidential customer details from information suitable for public release. Where a solution is proposed, discuss foreseeable trade-offs, including security, fraud management and the cost of implementation for smaller merchants.
Merchant associations can help aggregate experience, but individual examples still need accurate boundaries. Do not extrapolate a single provider dispute into a claim about an entire market without evidence. Equally, do not ignore a repeated issue simply because it appears in small transactions. A consistent record of frequency and impact can make a modest operational problem visible. The objective is a useful contribution to policy discussion, not a promotional statement about a preferred provider.
Independent analysis: retain evidence in a usable form
Create a compact evidence pack that can be refreshed without rebuilding it from scratch. Include the relevant contracts, recent invoices, a reconciled settlement sample and a log of unresolved service questions. Use a consistent period for comparisons and explain unusual trading events. Keep commercially sensitive documents accessible only to the people who need them, and prepare a separate redacted version if information will be shared outside the business.
Record the limitations of the data as carefully as the findings. If a report does not separate domestic from international cards, say so. If staff time was estimated rather than measured, label the estimate and explain the method. This makes the evidence more credible and identifies where future reporting should improve. A useful policy discussion can accommodate uncertainty; an apparently precise figure with an unclear basis is harder to evaluate. The same discipline improves internal decisions because management can see which conclusions are well supported and which still depend on assumptions that should be tested before committing money or changing customer-facing payment practices. Update the pack when circumstances change.
What it means to Merchants
Treat the RBA publication as a checkpoint in an ongoing review. Continue following requirements already in force while preparing reliable evidence on costs, access, reconciliation and switching. Keep consultation proposals separate from adopted rules and verify future dates through the regulator's publications. For your own payment decisions, use complete commercial comparisons and documented operating needs. Better evidence can improve provider discussions now and support informed participation later, without assuming that the review will deliver a particular price, service entitlement or regulatory outcome.