In payment parlance, every Acquirer must sit under a Sponsor bank that accepts settlement risk and enforces network rules. Most FinTech processors therefore depend on an external institution—which inserts extra fees, latency, and oversight. Adyen flips that script. As a principal member and licensed acquirer of both Visa and Mastercard, the company is its own sponsor. That status, rare among non-bank technology platforms, removes an entire layer of intermediation.

Yet through all these changes, one truth endures: successful strategies require more than just a spark of insight. They demand dedicated teams ready to execute and adapt.

As someone who has been fortunate to see and shape several transformations first- hand, I’m excited for what comes next. We’ve come a long way since 1987, and if the past is any indication, the future of payments promises even more dynamic and groundbreaking advances.

Over the years, the Merchant of Record (MoR) model has resurfaced repeatedly in the payments industry, driven by evolving regulations, global tax requirements, and the growing complexity of compliance obligations. Initially overshadowed by third-party processors and payment service providers, the MoR structure is reemerging as a strategic solution for e-commerce businesses seeking to streamline their billing and reduce operational overhead. By taking legal responsibility for the sale, MoR providers handle tax calculations, currency conversions, and liability management, simplifying processes for merchants across multiple markets.

In a recent turn of events, the Consumer Financial Protection Bureau (CFPB) revealed plans to rescind its May 2024 interpretive rule that would have classified some Buy Now, Pay Later (BNPL) products under the same regulatory framework as credit cards. This decision has left many in the FinTech and retail sectors wondering about the ramifications for compliance, product design, and consumer experiences.

All Acquirers must satisfy the control requirements under AACQ, irrespective of any additional archetype(s). This fundamental principle ensures that, no matter what the operating model, every Acquirer consistently adheres to the baseline standards needed to safeguard the payments ecosystem. Moreover, Acquirers must also meet the additional control requirements specific to their respective archetypes, reflecting the nuanced risks and obligations each model entails.

As of this writing, there is no finalized “Credit Card Competition Act 2025.” What has existed are various proposals, often referred to under this name, introduced in several congressional sessions. The following points assume a future scenario in which an expanded version of this Act is passed, leading to significant implications for Acquirers.