UK Finance response to the FCAs engagement paper highlighting a need for caution, consistency, and flexibility on contactless regulation.

In our response to the FCAs engagement paper on contactless limits, UK Finance members  emphasise that the current £100 single contactless limit remains appropriate, with the overwhelming majority of transactions falling well below this level. Members caution that raising the threshold would deliver little economic benefit while significantly heightening fraud risk, potentially incentivising card theft and undermining consumer trust. Fraud at present is tightly controlled, averaging just 1.3 pence per £100 spent. Industry consensus favours retaining a common single limit, though there are differing views on whether this should remain regulated by the FCA or be managed by industry through a coordinated framework. By contrast, there is broad support for removing background limits from SCA RTS, allowing issuers greater flexibility to apply risk-based controls aligned to their own portfolios. The adoption of Online PIN is highlighted as a promising step towards improving security, customer experience, and international interoperability.