Building a Resilient Payment Ecosystem and Consumer Trust— Speech by Director Domhnall Cullinan at Payments and E-Money Industry Seminar

While this is a speech rather than a new rulebook, compliance teams should treat it as directional intelligence on supervisory priorities. Firms should assess whether their resilience arrangements, consumer outcome monitoring and cash-access considerations are adequately documented and evidenced. Payment and e-money providers should also review fraud, AML/CFT and third-party dependency controls, as trust and resilience themes typically intersect with financial crime and outsourcing risks.

Actionable next steps include mapping the speech themes to existing governance forums, updating risk assessments, and preparing management information on consumer complaints, outages and incident response. Firms should consider whether product innovation and digital adoption are supported by robust customer disclosure and vulnerable-customer safeguards. No immediate implementation deadline is identified, but early alignment with supervisory expectations can reduce future engagement risk and support competitive positioning through stronger trust and service continuity.