Report

OBL publishes the Commercial Model for Variable Recurring Payments – Wave 1

09 April 2025

We are pleased to publish Commercial Model for Variable Recurring Payments Wave 1, the public consultation on the Wave 1 cVRP commercial Model report prepared by Frontier Economics for OBL.

Read the Frontier Economics report here
Download

OBL has also prepared a companion paper that summarises the report’s key findings, and which sets out key questions on the proposal and pricing (see below). You can read OBL’s summary here.

Your opportunity to respond

We are asking for feedback on the following questions. Please submit any written responses before close of business on 16 May 2025 via email or complete the online survey here.

KEY QUESTIONS
Q1: Does the proposal for the commercial model outlined in Frontier’s report adequately fit with the PSR and FCA pricing principles?
Q2: Does the proposal for the commercial model approach, in its current form, provide the best balance of the interests of participants being able to offer/use cVRPs without creating material barriers to inclusion or competition?
Q3: Does the proposed approach lead to proposed prices that allow ASPSPs to recover their expenses?
Q4: Does the proposed approach lead to proposed prices that are proportionate, objective and non-discriminatory?
Q5: Do you agree, or have any material concerns, about the assumptions and conclusions reached within the development of the approach to the proposed commercial model?
Q6: Do you think any of the commercial model price options would drive or prohibit the adoption of cVRPs by ASPSPs, PISPs, consumers, billers, merchants or other recipients under the Wave 1 use cases? Which of the pricing options would drive the right incentives through the value chain, as well as meeting the objective of consumer and business adoption? 
Q7: Do you think any final price should be (a) a fixed multilateral price, (b) a price cap with bilateral negotiation allowed below that cap, or (c) a fall-back price for any situation where bilateral negotiated prices cannot be independently reached?
(Note: Frontier has reserved its position on the legal framework required to ensure compliance with applicable competition law and we are discussing with our legal advisers. If you have views on the most effective approach, please provide them.)  
Complete the online survey here

We will consider your comments when preparing our response to this consultation.

We reserve the right to make all non-confidential responses to this consultation available for public inspection.

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