The two most detailed public reviews of card network (scheme) fees anywhere both found the fees had risen and competition was weak. Neither regulator capped them.

That's the part I think gets misread.

The UK Payment Systems Regulator closed its market review in March 2025. It found that core scheme and processing fees charged to acquirers had risen at least 25% in real terms between 2017 and 2023, costing UK businesses at least £170 million a year. It also found little evidence those increases were linked to cost changes, or that new fees were based on detailed cost analysis.

That is a clean case for a price cap, if a cap is the tool you reach for.

The PSR didn't reach for it. It selected three remedies instead: clearer fee information, documented pricing governance, and regulatory financial reporting.

Australia arrived somewhere similar from a different direction. The Payments System Board concluded that scheme fees, particularly on credit, were not subject to effective competitive constraints. Again no cap. Instead, quarterly public fee and rebate data from October 2026, and Scheme Fee Roadmaps expected by April 2027.

Two reviews, two legal systems, same answer. Make the pricing explainable rather than set it.

Here is why I think that matters well beyond those two markets.

A price cap would have been someone else's problem to implement. Explainability is not. If the direction is toward fee schedules you can classify, changes you get notice of, and invoices you can reconcile to transactions, then the work lands on the participant rather than on the network.

Which makes "regulation will eventually deal with my network fee costs" a bet on the wrong thing. What is actually happening is that the standard for what a participant should be able to explain is being written down in public, in detail, by more than one regulator at a time.

Worth asking what you could produce today if someone asked you to justify a material movement in your network fee line. Not to comply. Nobody is asking. But it is the same evidence you would need to challenge a charge, and most institutions cannot assemble it quickly.

That's one strand of a briefing I've put together on what regulators across seven markets have concluded. Every figure sourced. Ask in the comments and I'll send it or see our CardTraq website for the full download.

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