Wholesale Retail Code Change Proposal – Ref CPW122

Date03 May 2022
1
Wholesale Retail Code Change Proposal Ref CPW122
Modification
proposal
Wholesale Retail Code Change Proposal CPW122 Introducing
Direct Debit as a payment method
Decision
The authority has decided to reject this change
Publication date
3 May 2022
Implementation
date
N/A
We are rejecting this Change Proposal.
We are rejecting this Change Proposal on the basis that the Final Report did not clearly
articulate that the benefits of the solution for customers outweighed the added
complexity and costs associated with the transfer of administrative costs from Retailers
to Wholesalers. We do not consider that the Final Report fully assessed the impact that
this proposal may have on trading parties, both in terms of implementing the solution
and meeting the new requirements on an ongoing basis.
We support the principle of Retailers being offered alternative payment methods where
doing so carries with it benefits for current and future customers, including by
removing unnecessary costs and inefficiencies from the existing market arrangements.
We encourage Wholesalers, in demonstrating their commitment to supporting the
business retail market, to take this into consideration when reviewing proposals from
Retailers.
We do, however, suggest that if this concept is revisited in the future it should seek to
take account of latest developments in the payment systems sector and include
convincing evidence on the levels of potential take up across Retailers and articulate
how the solution would benefit, either directly or indirectly, end customers.
We acknowledge that running a pilot of the solution could be a reasonable approach to
test the use of Direct Debit and gather further data and evidence on the potential
benefits and impacts of implementing the solution. Though we were concerned with
the feedback from the Panel which suggested that there was not enough information
gained during the consultation to develop a robust plan for a meaningful pilot exercise.
It was also unclear from the evidence provided that there was strong enough interest
in the solution to take it forward in its current form.

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