Pay by Bank gambling payments UK compliance guide

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How the verified Pay by Bank flow works

Open Banking Limited describes Pay by Bank as an account-to-account online payment. The customer approves the payment using a bank app or online banking, rather than the payment being established merely by a merchant displaying the method.

According to Open Banking Limited, a regulated payment initiation service provider connects the merchant and the customer’s bank through open-banking APIs. Customer consent is part of that described connection. These points explain the payment flow, but the supplied evidence does not establish fees, transaction limits, processing speed, settlement timing, supported banks or availability at any named operator.

• The payment is described as moving from one bank account to another.
• The customer approves it through a bank app or online banking.
• A regulated payment initiation service provider connects the merchant and bank through open-banking APIs.
• The connection described by Open Banking Limited depends on customer consent.

Why gambling compliance checks remain separate

The UK Gambling Commission says that a business providing remote gambling facilities to consumers in Great Britain needs its operating licence. This requirement concerns the gambling business; it is not replaced by the way a customer initiates or approves a bank payment.

The Commission also states in licence condition 5.1.2 that applicable remote gambling licensees must accept customer payments through qualifying payment service providers. Payment and compliance teams therefore need to examine the operator and the relevant provider relationship separately from the general description of the Pay by Bank flow.

• Check the gambling operator’s position using current, direct evidence rather than inferring it from the payment rail.
• Assess whether licence condition 5.1.2 applies to the remote gambling licensee under review.
• Verify that the payment service provider meets the relevant qualifying requirement before relying on the payment arrangement.
• Do not treat bank-app approval as evidence that a gambling operator holds an operating licence or accepts Pay by Bank.

What the payment rail does not prove

The supplied evidence explains the general payment mechanism and selected Gambling Commission requirements. It does not identify a casino, betting business or other operator that currently offers Pay by Bank. It also does not establish commercial availability for a particular merchant.

A bank-app approval confirms the customer action described by Open Banking Limited within the payment flow. It should not be presented as proof of operator acceptance, gambling licensing, provider qualification or the outcome of a transaction. Each of those questions requires evidence specific to the operator, provider and proposed arrangement.

• No named gambling operator’s acceptance is established by the supplied facts.
• No fees, limits, speeds, settlement periods or supported-bank lists are established here.
• No operator or payment provider is ranked, recommended or described as tested by GambleView.
• The payment flow and the gambling regulatory checks should remain distinct in an internal assessment.

A practical review framework

Payment teams can begin with the documented Pay by Bank journey: account-to-account payment, customer approval through a bank app or online banking, and connection through a regulated payment initiation service provider using open-banking APIs with consent. Compliance teams can then review the gambling business and payment-provider arrangement against the separate Commission statements.

This sequence helps keep the evidence categories clear. The payment description answers how the customer initiates the payment. The Commission material addresses the operating-licence requirement for businesses providing remote gambling facilities to consumers in Great Britain and the payment-service-provider condition for applicable remote gambling licensees. Neither category supplies current operator-level acceptance evidence.

• Document the customer approval stage described for Pay by Bank.
• Identify the payment initiation service provider in the proposed merchant flow.
• Review the remote gambling business’s operating-licence evidence where the Great Britain requirement applies.
• Review the relevant payment service provider against licence condition 5.1.2.
• Obtain direct, current operator evidence before recording Pay by Bank as accepted.