Finopotamus Int'l: Payments Reform’s Hardest Phase – Turning Strategy into Working Infrastructure

Guest Editorial by Young Pham, Chief Strategy Officer, CI&T

Ask anyone who has delivered a national payments platform what they’re most proud of, and they rarely point to the strategy document. They’ll talk about the Tuesday morning when a settlement glitch got caught and fixed before it reached customers, or the month they spent reworking fraud rules because real transaction patterns taught them something the models hadn’t predicted. Strategy gives you a direction. Delivery is where you find out whether the direction was any good.

The UK finds itself at exactly that junction right now. After a year dominated by debate over objectives, governance structures and regulatory alignment, the Payments Vision Delivery Committee published its Strategy for Future Retail Payments Infrastructure in November 2025. 

That document confirmed how HM Treasury and the authorities plan to coordinate over the years ahead and, importantly, it acknowledged something practitioners have long understood: choices about system design, sequencing and daily operation tend to become permanent once infrastructure goes live. 

The Bank of England’s Payments Forward Plan arrived in February 2026, adding further shape and setting out a sequence of initiatives across both retail and wholesale payments. Together, these documents signal that the UK is moving past vision-setting and into the phase where real commitments get made. Banks, fintechs and end users all inherit the consequences of what gets decided now.

With the strategic layer now largely settled, attention naturally shifts to a different set of problems. How are direct connections managed? Where does responsibility sit when something breaks at volume? How do new rails run alongside legacy systems without creating friction or confusion for the businesses and consumers who rely on both? These are build-phase questions, and they are best answered by looking at countries that have already faced them.

Brazil’s PIX: a Reference Point, Not a Blueprint

The National Payments Vision itself highlights Brazil’s PIX as an example of instant payments operating at genuine national scale. That reference is well placed. Unlike many schemes that have launched tentatively and grown incrementally, PIX was designed to serve as a primary payment method across the entire economy from its launch in 2020. The Central Bank of Brazil mandated participation from major financial institutions on a fixed timetable, which left no room for a slow ramp-up. The system had to absorb real volume from day one.

What that meant in practice was enormous internal work at participating banks. Core platforms needed to run continuously, with no overnight batch windows to fall back on. Routing had to accommodate new identifiers, including mobile numbers and QR codes, alongside traditional account details. Fraud detection and settlement had to operate in real time across customer journeys that had, until recently, been built around slower, more predictable cycles. Most of that effort happened deep inside bank infrastructure, well away from the consumer-facing layer.

PIX adoption grew quickly once people started using it for ordinary things: splitting a restaurant bill, paying a plumber, settling up with a landlord. By 2024, it was handling upwards of 60 billion transactions annually. It had stopped being a payment option and had become the default way Brazilians move money.

That is when the more interesting phase began. Once PIX became embedded in everyday behaviour, early design choices started to reveal their practical limitations. Transaction limits that seemed reasonable during testing sometimes created friction for merchants at peak trading times. Fraud patterns evolved as usage increased. Questions around liability questions, which had been largely theoretical during planning became operational matters that compliance and operations needed to address in real time.

The lesson from Brazil is not that PIX was perfect from the outset. What stands out is how reliability, coordination between institutions and operational discipline became more important than the technical architecture itself. As instant payments became embedded in everyday economic activity, the focus increasingly moved to keeping the system running smoothly and consistently. Infrastructure of this kind begins to resemble a utility, and utilities are ultimately judged on uptime, not ambition.

The UK is entering a comparable phase. Direction has been agreed. Build is coming into focus. The questions that dominate from here will be practical: how does this infrastructure hold up under sustained daily use, at volume, and when things go wrong?

Inclusion Follows from How a System Runs, Not What It Promises

One thing that stands out from every large instant payments rollout is that financial inclusion outcomes are shaped more by operational reality than by policy language. The access rules a system sets, the pricing it applies, the onboarding requirements it enforces - these are the things that determine who actually use the infrastructure day to day. Good intentions in a strategy document count for very little if the system is too expensive, too complex or too unreliable for smaller players to depend on.

In Brazil, PIX gained traction with individuals and small businesses largely because it was cheap and widely available. People didn’t adopt it because of an inclusion programme. They adopted it because it was easier and cheaper than the alternatives for everyday payments. That organic uptake, driven by practical economics rather than top-down mandates, is arguably more durable than any targeted intervention could have been.

The UK’s context is different, obviously, but some of the underlying tensions look similar. Small businesses still face real cost and complexity in managing multiple payment methods. Cash remains important for significant portions of the population. And a good deal of digital payment innovation over the past decade has been optimised for the mainstream rather than designed with accessibility front of mind.

Whether the UK’s new payments infrastructure genuinely broadens participation will come down to decisions made during build and early rollout. How onboarding works, what it costs, how the system performs when transaction volumes spike - these practical details will determine whether new rails become part of normal commercial life or remain a secondary channel.

Risk Concentrates Differently at Speed

Fraud followed PIX adoption, as it follows any successful payment method. No one was surprised by that. What mattered was the response: how quickly responsibility was assigned, how monitoring evolved, and how transaction controls adapted to the patterns that emerged from actual use rather than from pre-launch modelling.

Instant payments behave differently to batch systems when it comes to risk. Mistakes propagate faster. Irreversible transfers mean the window for intervention is narrow. And the operational discipline required to manage fraud, errors and disputes in real time is qualitatively different from what most institutions have been staffed and structured to handle.

These pressures don’t typically show up on day one. They build gradually as volumes increase and usage patterns settle. They are rarely resolved during design. Instead, they’re managed through governance, inter-institutional coordination and continual adjustment once the system is carrying real weight.

For the UK, clarity on operational responsibility will be essential as new infrastructure comes online. Confidence in a payments system - the kind of confidence that lets businesses and consumers use it without a second thought - depends far less on published safeguards than on how well institutions coordinate when something goes wrong.

Where This Gets Decided

The UK’s National Payments Vision laid out an ambition but what ultimately matters is the execution. The next twelve to eighteen months will shape how the UK’s payments infrastructure behaves for a generation. Not because of any single policy announcement, but because of hundreds of smaller decisions about architecture, sequencing, participation models and operational governance that will quietly lock in outcomes long before most stakeholders realise they’ve been made.

Those who have built these systems at national scale know what this phase feels like. They know which trade-offs bite hardest, which shortcuts create problems three years later, and where the gap between a well-drawn plan and a well-run system tend to open up. The UK has the benefit of watching others go first. Using that advantage well means taking the build seriously, because the build is where payments reform either works or doesn’t.

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Young Pham is the Chief Strategy Officer for CI&T. He has provided digital delivery strategy for over 30 years, specifically with a focus in financial services.  He’s previously led digital product teams at JP Morgan Chase and also co-founded separate venture back startups in mortgage and investing.  At CI&T, Young is responsible for helping clients create distribution, customer experience, and payments strategies for clients such as Wells Fargo, BlackRock, Invesco and Chase. Most recently, he has been advocating for how AI will transform the financial services industry while also creating greater accessibility to banking for all consumers.