A Working Link Needs Permission, Oversight, and Trust

A cross-border payment path can be technically connected and still be unavailable, unsafe or difficult to supervise. The focus here is the governance layer: who is allowed to participate, which authorities oversee the payment system and its interlink, and when payment information may cross a jurisdictional boundary. Seeing these as operating conditions—not as paperwork added after the technology—is essential for judging whether a fast connection can work reliably at scale.

The word “permission” has several parts. A provider may need to be eligible for access. A payment system may need authority to share information with a linked system or a relevant public body. Supervisors may need a way to monitor banks, non-bank payment service providers and the connection between them. The participants may also need a common understanding of which institution is responsible when a payment is delayed, rejected or suspected of fraud. A technical route without these permissions is only a possible route.

Oversight follows the path across jurisdictions

Start with a bilateral link between two fast payment systems. Each system operates within a home jurisdiction, with its own eligibility rules, supervisory expectations and controls. The link creates an additional relationship that crosses the border. Authorities must then decide how the systems and the interlink will be overseen, how concerns will be shared, and which rules apply when the responsibilities of the two sides do not line up perfectly.

The CPMI survey treats this as a central part of payment-system improvement. By the end of 2025, 58% of jurisdictions surveyed had established cross-border-payment oversight frameworks, while another 10% planned to introduce them. Thirty-one percent reported no current plans to issue such expectations. Most existing frameworks—60%—used a risk-based approach, tailoring expectations to the seriousness of the risks, the scale of the business and the operational complexity of the provider. The survey also reports that 64% of jurisdictions monitored compliance through on-site and off-site inspections, while only 5% had introduced real-time monitoring tools.

These figures do not say that a jurisdiction without a dedicated framework has no payment controls. They indicate whether authorities reported a framework specifically related to cross-border payment services. Nor does a framework’s existence prove that two jurisdictions’ rules are compatible in practice. It does show why a new connection may require more than an agreement between payment-system operators. The authorities responsible for access, supervision and data use must be able to recognise the arrangement and act when its risks change.

The governance problem becomes clearer when the link itself is considered. The BIS brief reports that, for all bilateral FPS links in the survey, the competent authority in the home jurisdiction had oversight responsibility for the FPS. Most of those systems also reported that the home jurisdiction had oversight responsibilities for the interlinking arrangement. Six FPS reported some form of cooperation with overseers in the linked jurisdiction, through formal or informal arrangements. Two reported no cooperative oversight arrangement.

Cooperation does not require every authority to become the same authority. It requires enough coordination to make the cross-border relationship observable and accountable. A home supervisor may know how a domestic system operates, while the linked authority understands the providers and rules on the other side. If a problem crosses that boundary, a purely domestic view can miss the part of the path where the risk is developing.