CMA: CASS Remedies Undertakings Retained to Boost UK Banking Competition

• The Competition and Markets Authority (CMA) has retained the Current Account Switch Service (CASS) Remedies Undertakings.
• This decision was finalized on November 4, 2026, following a review by the CMA.
• The undertakings require Pay.UK to make changes to the CASS as mandated by the CMA retail banking market investigation.
• The CMA investigation identified competition problems in both personal current account and SME banking markets.
• These undertakings are part of a broader package of remedies designed to address those competition issues.

For legal and compliance professionals advising financial institutions operating within the retail and SME sectors, this confirms the ongoing nature of the regulatory obligations directly tied to the Current Account Switch Service.

The Competition and Markets Authority (CMA) has officially confirmed the retention of the Current Account Switch Service (CASS) Remedies Undertakings, following a comprehensive review process. This pivotal decision, which saw the CMA publish its final determination on November 4, 2026, ensures the continued enforcement of specific obligations initially placed upon Bacs. These undertakings specifically commit Bacs to implement various modifications and enhancements to the CASS framework, directly addressing requirements that emerged from the CMA's extensive retail banking market investigation. The outcome of this review underscores the regulator's sustained focus on fostering a more competitive environment within the UK's financial sector, particularly concerning current account services.

The review process meticulously assessed the ongoing relevance and effectiveness of these undertakings, concluding that their retention remains essential for achieving the intended regulatory objectives. Consequently, Pay.UK, as the entity responsible for operating the Current Account Switch Service, is mandated to persist in its efforts to enact the necessary changes. This reinforces the existing regulatory landscape for current account providers and ensures that the foundational principles of competition continue to be upheld in the UK banking market.

The origins of these crucial undertakings are firmly rooted in the findings of the CMA's in-depth retail banking market investigation. This significant inquiry meticulously identified and documented a series of competition deficiencies that were adversely affecting both personal current account (PCA) and small and medium-sized enterprise (SME) banking markets across the United Kingdom. These identified issues were deemed substantial enough to warrant a robust regulatory response aimed at stimulating greater market dynamics and enhancing consumer choice.

The CASS Remedies Undertakings represent a vital component within a broader package of corrective measures that the CMA designed to systematically address these identified competition problems. Their fundamental purpose is to facilitate smoother and more efficient transitions for customers moving between different banking providers, thereby actively stimulating greater rivalry and innovation among financial institutions. The investigation's comprehensive conclusions unequivocally highlighted the necessity of implementing both structural and operational improvements to ensure that the banking sector operates more effectively and fairly for both individual consumers and businesses.

The Competition and Markets Authority's decision to retain the CMA CASS Remedies Undertakings carries substantial and enduring implications for the competitive landscape of UK banking. For legal and compliance professionals advising financial institutions operating within the retail and SME sectors, this confirms the ongoing nature of the regulatory obligations directly tied to the Current Account Switch Service. It distinctly underscores the necessity for continued, diligent adherence to the competition-focused requirements that were initially established to rectify identified market imbalances and promote greater consumer welfare.

The sustained enforcement of these undertakings means that Pay.UK, along with all banks actively participating in the Current Account Switch Service, must maintain their unwavering focus on facilitating efficient, transparent, and effective account switching processes. This consistent regulatory pressure is strategically designed to ensure that the mechanisms enabling customers to switch accounts remain robust, accessible, and user-friendly. The retention of these remedies reinforces the CMA's long-term strategic commitment to cultivating a more dynamic and genuinely competitive banking environment, ultimately benefiting customers through improved services, greater innovation, and expanded choice. The Competition and Markets Authority's steadfast commitment to these remedies highlights the critical role of the CASS in driving healthy competition within the financial sector.

Lawyers and compliance officers advising financial institutions in the UK's retail and SME banking sectors should note that the Competition and Markets Authority has retained the CASS Remedies Undertakings. This confirms the ongoing regulatory obligations for Bacs and, by extension, banks participating in the Current Account Switch Service, necessitating continued adherence to these competition-focused requirements.

Source: Original reporting via GOV.UK guidance