Priya Jaiswal is a distinguished voice in the financial sector, bringing over twenty years of experience in market analysis and international business trends. As a recognized authority on banking strategy, she has spent her career navigating the complex intersection of traditional institutional stability and the disruptive forces of modern fintech. In our discussion, she provides a deep dive into the shifting European regulatory landscape, the friction between legacy systems and innovation, and the urgent need for banks to move beyond a “checklist” mentality to embrace true operational resilience.
The following conversation explores how regulatory convergence is raising the bar for accountability across the entire value chain. We discuss the hidden costs of digital transformation, the rise of agentic commerce, and why the “spirit of the law” is becoming more important than the letter of the law for institutions aiming to survive in a real-time economy.
Regulatory trends over the last two decades have shifted from simple checklists to a focus on transparency and resilience. How has this evolution redefined the “art of the possible” for banks, and what specific operational trade-offs do firms face when moving beyond basic compliance?
For twenty years, I have maintained that regulatory convergence is not accidental; it is a relentless raising of the expectations bar that redefines what we can—and should—achieve. Regulators have essentially decided that technological change determines the “art of the possible,” forcing banks to move away from treating compliance as a standalone checklist to be ticked off. This shift creates a massive operational trade-off: banks can no longer just aim to be “compliant enough,” which has been an industry staple for decades. Instead, they must invest in deep-seated transparency and reporting systems that often feel like “madness” because they exceed the immediate letter of the law. This evolution requires a pivot from seeing regulation as a hurdle to seeing it as a blueprint for a more resilient, albeit more complex, business model.
Legacy systems are often fully amortized and functional, making the transition to API-first architectures or cloud strategies costly. What are the practical steps for a traditional institution to balance these sunk costs against new mandates, and how does this friction impact their long-term competitiveness?
The friction stems from the fact that many banks are still using infrastructure that is done, built, paid for, and fully amortized—and importantly, it still works. Every time a new mandate like PSD2 or CASS arrives, it forces an institution to stop what it is doing, pay for new systems, and endure the period where costs go up while margins inevitably go down. To balance this, banks must recognize that their data discipline and API-first strategies were often born out of necessity rather than choice, yet these are now the very tools required for basic competitiveness. The practical step is to stop viewing these upgrades as one-off expenses and start seeing them as the price of admission for the future of open finance. If you don’t drag yourself into the future now, the cost of being dragged there by a regulator later will be significantly higher in terms of lost market share and technological debt.
Accountability is now expanding across the entire value chain to include telecommunications providers and payment schemes. How do concepts like representation fraud or behavioral factors change the way you manage partnerships, and what metrics should be used to measure the success of this shared responsibility?
We are seeing a massive shift where regulation is leaning into the wider payments ecosystem, pulling in everyone from telcos to schemes into the accountability loop. When you introduce concepts like representation fraud and behavioral factors being recognized as “inherence,” the old boundaries of where a bank’s responsibility ends and a partner’s begins start to blur. This means we have to manage partnerships with a much higher degree of “systems awareness,” ensuring that every hand-off in the value chain is as secure and transparent as the internal processes. Success should be measured by the speed and accuracy of unconditional refund rights for merchant-initiated transactions and the overall resilience of the shared infrastructure. It is no longer about how well you do your part, but how confident you are in the collective integrity of the entire ecosystem.
Emerging trends like agentic commerce and stablecoin rails often move faster than the gestation period of new legislation. How should organizations interpret the spirit of existing rules to prepare for autonomous transactions, and what specific scenarios might render current cross-border interoperability provisions inadequate?
The reality is that some regulations, like the Payment Services Regulation (PSR), were intended to be future-proof but are already silent on things like agentic commerce because the legislative process is simply too slow. We are entering a world where agents might transact with each other using native stablecoin rails, completing and settling transactions in the blink of an eye. In this environment, current cross-border interoperability provisions could become inadequate the moment autonomous agents begin bypassing traditional clearing houses altogether. Organizations must stop waiting for a specific rulebook and instead lean into the known “regulatory direction” of transparency and accountability. You have to take a proactive view on how your infrastructure will handle these near-instant, autonomous interactions before the next wave of regulation makes it a mandatory, and likely more expensive, requirement.
Shifting to real-time, transparent infrastructure requires a fundamental change in how a company is understood and managed. What anecdotes can you share regarding the difficulty of implementing instant payment mandates, and how can teams demonstrate they truly understand the assignment of building resilient systems?
Implementing instant payment mandates is often a “half-day, technical deep-dive” kind of struggle because it exposes how little some teams actually understand about their own “shop.” I’ve seen sessions where the sheer volume of regulatory intent leaning into different bodies of legislation becomes overwhelming, leaving teams feeling like they are training for a marathon while already mid-race. To demonstrate they “understand the assignment,” teams need to show more than just a functioning payment rail; they need to show they have built a system that accounts for resilience and accountability at every touchpoint. It’s about being able to show up for clients with a platform that is not just fast, but inherently stable and transparent. This is what we have been training for over the last two decades—moving from “box-ticking” to actually owning the infrastructure we operate.
What is your forecast for the European payments regulatory landscape?
The shortest answer is that the landscape will remain incredibly “busy” and will only continue to grow in complexity as different bodies of legislation begin to actively lean into each other. I forecast a period where the “spirit of the law” becomes the dominant guiding principle because technology is moving too fast for the “letter of the law” to keep up. We will see more aggressive enforcement regarding the wider value chain, especially as regulators try to close the gap on agentic commerce and stablecoins. My advice for readers is to stop looking for the next checklist and start building the most resilient, transparent infrastructure possible today. The time for guessing is over; the future belongs to those who treat these regulatory shifts as a declaration of intent for a real-time economy.
