Repeat payments without cards: where open banking now fits

By Sarah Abernethy, Co-director · 9 November 2026 · 5 min read

For years, open banking was good at one-off "pay by bank" checkouts and awkward at everything after: top-ups, renewals and variable invoices usually meant sending the customer back into their banking app. That is why cards and Direct Debit still run most recurring revenue.

That gap is closing. On 4 November 2026, investment platform Trading 212 said it had completed automated deposits using TrueLayer's Bank on File, so customers can fund scheduled investments from their bank without logging into their banking app each time. TrueLayer reports a 97% first-attempt success rate since the feature went live in June — TrueLayer's own figure, worth treating as a provider claim until you see your own numbers.

The commercially important bit is repeatability: set consent once, then take eligible subsequent payments without fresh authentication each time.

What Bank on File and commercial VRP actually are

Bank on File is TrueLayer's name for a recurring and one-click open banking payment. Underneath it sits commercial Variable Recurring Payments, or cVRP: the customer authorises a business, through their own bank, to collect payments of varying amounts within agreed limits. Further payments inside those limits can go through without approving each one. Money moves account-to-account, usually over Faster Payments, so settlement is near real time. The customer can review or cancel the mandate in their banking app.

Different from a card on file, where you store card details (or a token) and charge later, and from Direct Debit, which is built for scheduled collections but typically takes days to clear and is less flexible when the amount changes often.

Open Banking Limited describes two flavours: sweeping VRPs move money between accounts the same person owns; commercial VRPs pay a business. Trading 212's case is commercial.

Where it fits next to cards and Direct Debit

If you take card payments today, you do not need to rip anything out. Cards still matter for first-time checkout, guest buyers, international customers and any sale where chargeback protection is part of the customer promise.

What has changed is the option set for repeat money movement: account top-ups; subscriptions where the amount can change; invoice collection and usage-based billing; and other variable repeats that sit between a standing order and a card continuous payment authority.

For those journeys, open banking is closer to stored-card convenience, with faster settlement than Direct Debit and no card expiry to chase. Model it alongside cards and Direct Debit, not instead of them. We spend most of our time helping UK businesses cut card costs and find the right acquirer — treat a new rail the same way: test it, don't adopt it as a slogan.

What to test before you trust the headline numbers

A 97% success rate sounds excellent. It may well be for Trading 212's customers and banks; your mix will be different. Work through these checks first.

Bank coverage. TrueLayer says all six of the UK's largest banks are live for this Trading 212 deployment. Your customers will not all bank with the big six, and coverage still varies by provider and use case. Ask which banks are live for the exact product you want.

Consent, renewal and recovery. Mandates have limits and end dates; customers can cancel in their banking app. Map expiry, revocation and limit increases. Cards have a mature decline-and-retry playbook; open banking failures look different — insufficient funds, bank outages, mandate mismatches. Ask how failed payments are surfaced and what a clean retry looks like.

Refunds and disputes. The main commercial trade-off. Card chargebacks and Section 75 rights do not apply to Variable Recurring Payments, and neither does Direct Debit Guarantee protection. Customers still have rights under the Payment Services Regulations for unauthorised or incorrectly executed payments, and ordinary consumer law still applies to the purchase. But if goods are not delivered or a service falls short, redress is largely between you and the customer — for some products that is fine; for others, cards remain the safer promise.

Reconciliation, real rates and rollout fit. Near-real-time settlement helps only if finance can match the payment to the invoice or top-up. Ask for usable references and status data, then for success rates by bank and by new versus returning mandate — not a blended average. Commercial VRP is live through the UK Payments Initiative scheme in phases; early waves focused on lower-risk use cases such as regulated financial services, utilities and public-sector payments. Check whether your sector and payment type are in scope.

Cards are not going away

The Bank of England's recent work on the UK's next retail payments infrastructure makes the same point: better account-to-account rails help, but infrastructure alone does not create a full alternative to cards. Refunds, disputes, liability and sustainable merchant incentives still have to be sorted at product and scheme level.

Keep cards where they earn their keep, use Direct Debit where scheduled collections still fit, and test Bank on File or commercial VRP where repeat customers, variable amounts and fast settlement would help. Measure your own numbers before you move volume.

For who sits where in the card chain, see Payment gateway, acquirer, processor: who does what?. For your next provider meeting, What your FD should ask your acquirer at the annual review is a useful starting list.

One-page checklist: is open banking ready for your repeat payments?

Take this into your next payments review.

  • Which of our payment journeys are truly repeat: top-ups, subscriptions, invoices, usage billing?
  • For each journey, what do we use today: card on file, Direct Debit, standing order, or manual pay-by-bank?
  • Which banks do our customers use, and which are live for Bank on File / cVRP with our provider?
  • What are the mandate limits, end dates and customer cancellation paths?
  • What happens on a failed payment, and how do we recover it?
  • How do refunds and purchase disputes work without card chargebacks?
  • Can finance reconcile these payments to the right customer and invoice?
  • What success rate do we need on our own traffic before we move real volume?

Not sure how this sits next to what you already pay for cards? Send us a statement and we'll walk you through the card side first.

Want a hand?

We've spent two decades in payments and work with 40+ acquirer partners — mostly on card costs and acquiring set-ups. Open banking is one more option on the table, not a reason to ignore the card statement.

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