The Bangko Sentral ng Pilipinas is tightening its oversight
of digital payment charges, signaling that the era of arbitrary electronic
transfer fees is coming to an end.
Following the expiration of the moratorium on increases in
InstaPay and PESONet charges, the central bank has introduced a regulatory
framework that compels banks and other BSP-supervised financial institutions to
substantiate the fees they impose on consumers. Rather than allowing pricing
decisions to rest solely on commercial discretion, the new rules require
institutions to demonstrate that their charges reflect the actual cost of
delivering digital payment services.
The policy, contained in a circular signed by BSP Governor
Eli Remolona Jr. and approved by the Monetary Board, establishes formal
standards governing person-to-person electronic fund transfers under the
National Retail Payment System.
At the heart of the directive is a simple principle.
Convenience should not become an excuse for excessive pricing.
Financial institutions must now adopt a documented fee
policy supported by quantitative analysis. They are expected to show the basis
for every electronic payment charge and prove that the amounts collected are
aligned with operational realities. The BSP described the required approach as
a reasonable and fair market-based pricing mechanism grounded in the genuine
costs of providing digital financial services.
In practical terms, banks and payment service providers
retain the ability to revise transfer fees. However, any adjustment must
withstand regulatory scrutiny and be supported by evidence rather than
assumption.
The circular also addresses a long-standing concern
involving differences between on-us and off-us transactions. On-us transfers
occur when both sender and recipient maintain accounts within the same
institution, while off-us transactions involve separate financial entities. The
BSP stated that fees for off-us transfers should not substantially exceed those
charged for on-us transactions, except for switch costs directly attributable
to processing payments across different institutions.
The distinction is significant because payment systems
function much like interconnected transport networks. A slightly higher toll
may be justified when a transaction travels through an external switch, but
consumers should not bear inflated charges simply because their money crosses
institutional boundaries.
Equity among users also forms a cornerstone of the new
framework. Fee structures must be designed in a manner that prevents one group
of customers from unfairly subsidizing another. According to the BSP, pricing
models should uphold fairness across all end-user segments and avoid creating
unreasonable cross-subsidization.
Consumer protection provisions further strengthen the
policy. Recipients of person-to-person electronic fund transfers must receive
the full amount intended for them, without deductions or hidden charges applied
upon crediting. The amount sent should be the amount received.
The central bank likewise emphasized that digital
transactions, by their nature, should generally cost less than manual or
over-the-counter alternatives. Since electronic channels are more efficient and
involve lower processing burdens, consumers are expected to benefit from more
economical pricing structures.
Beyond transfer fees, the BSP expanded its regulatory reach
to merchant payment acceptance activities. Operators of Payment Systems holding
Merchant Acquisition Licenses must implement fee schedules that are
transparent, proportionate, market-based, and reflective of the actual services
rendered to businesses.
In a separate circular issued alongside these pricing rules,
the BSP also laid down standards for digital financial marketplaces. Banks and
electronic money issuers seeking to operate such platforms must first secure
approval from the central bank.
These marketplaces are required to offer consumers genuine
choice. At least three participating providers that are independent of the
operator's corporate group must be represented on the platform. Prospective
operators must also possess an advanced electronic payments and financial
services license, robust information technology capabilities, comprehensive
risk management frameworks, and a minimum net worth or combined capital of P1
billion.
Taken together, the twin circulars underscore the BSP's
broader objective of building a digital financial ecosystem that balances
innovation with accountability. As electronic transactions become increasingly
embedded in everyday life, the regulator is making clear that accessibility and
efficiency must be matched by transparency, fairness, and consumer trust.
Both circulars will take effect 15 calendar days after their publication in the Official Gazette or in a newspaper of general circulation.
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