For over a decade, the relationship between UK merchants and payment service providers (PSPs) has been notoriously one-sided. Small businesses frequently woke up to find their accounts frozen or terminated with little warning and even less explanation. This phenomenon, often termed "debanking," became a systemic risk for high-risk sectors and innovative startups alike.
However, as of April 28, 2026, the regulatory landscape has shifted. Under the Payment Services and Payment Accounts (Contract Termination) (Amendment) Regulations, the UK government has mandated a new level of transparency and fairness. This guide explores every facet of the "90-Day Rule" and its implications for your business continuity.
1. Understanding the Legal Framework: Why 90 Days?
Before this amendment, the standard notice period for account termination was a mere 60 days. While 60 days sounds substantial, in the world of enterprise finance, it is often insufficient time to source, vet, and integrate a new payment processor—especially for businesses in "high-risk" categories like travel, CBD, or gaming.
The 2026 regulations extend this to 90 days to allow for a "fair transition." Crucially, the law now requires the provider to provide a "sufficiently detailed and specific" reason for the termination. The era of the vague "commercial decision" letter is officially over.
2. Who is Protected Under the 2026 Rules?
The scope of these regulations is broad, covering almost all entities regulated by the Financial Conduct Authority (FCA). This includes:
- Traditional Banks: High-street banks providing business current accounts.
- Electronic Money Institutions (EMIs): Popular "neobanks" and digital wallets.
- Payment Processors (PSPs): Third-party aggregators like Stripe, Square, and SumUp.
Whether you are a sole trader or a mid-market corporation, if your provider is FCA-regulated, they are bound by these notice requirements.
3. Deep Dive: Impact by Industry
| Industry Sector | Impact of the 90-Day Rule | Strategic Advantage |
|---|---|---|
| High-Risk (Gaming/CBD) | Prevents sudden "de-risking" sweeps. | Ample time to provide compliance audits to new providers. |
| AI & Tech Startups | Stops AI-driven "false positive" bans. | Allows for human review and appeal of automated terminations. |
| B2B Wholesalers | Protects long-term cash flow cycles. | Ensures payroll and supplier payments aren't disrupted mid-month. |
4. The "Immediate Termination" Exceptions
It is vital to understand that the 90-day rule is not absolute. Providers can still terminate an account instantly if they can prove one of the following:
"The 90-day notice period may be waived in cases involving suspected financial crime, including money laundering, terrorist financing, or clear breaches of the Proceeds of Crime Act 2002."
If your account is closed for these reasons, the provider is legally barred from "tipping off," so they may still be unable to provide a full explanation during an active investigation.
5. Step-by-Step: What to do if you receive a 90-Day Notice
- Request the "Detailed Reason": Immediately cite the 2026 Amendment and ask for the specific breach or risk factor that triggered the notice.
- Audit Your Risk Profile: Review your recent chargeback ratios, average transaction values (ATV), and geographic sales data.
- Secure a "Backup" Provider: Use the 90-day window to apply for 2-3 alternative merchant accounts. Do not wait until day 60.
- File an Internal Complaint: Every provider must have a formal complaints process. Exhaust this before moving to the Ombudsman.
- Contact the Financial Ombudsman: If you believe the termination is discriminatory or based on a misunderstanding of your business model, the FOS can now intervene under the new transparency guidelines.
6. Conclusion: A New Era of Merchant Security
The 90-day rule represents the most significant win for UK business owners in a decade. While it doesn't guarantee you a "bank account for life," it does guarantee you the time and information needed to protect your livelihood.
