G20 Roadmap for Enhancing Cross Border Payments: Scorecard Report on Direct Access and Price Transparency (Wise)

Summary

• Research by Consumers International indicates that 57% of consumer bodies cite a lack of fee transparency as a primary reason behind consumer distrust in digital finance.p.10
• US consumers are projected to lose $19 billion in obscured FX markups in 2025, with annual losses potentially expanding to $46 billion by 2027.p.12
• Australian consumers are expected to lose nearly $4 billion in hidden cross-border payment fees in 2025 due to the absence of mandatory markup rules.p.12
• Canadian consumers are projected to lose an estimated $1.2 billion in 2025 as a result of obscured foreign exchange markups.p.27
• Indian consumers and SMEs face projected losses of $7 billion in 2025 from FX markups, a figure rising to $8.9 billion by 2027.p.33
• Brazilian consumers and SMEs are expected to lose over $3 billion in hidden fees when sending cross-border payments in 2025.p.24

Key insights

1. The United Kingdom became the only market to achieve a 5/5 score for price transparency following new FCA guidance requiring explicit disclosure of FX markups as costs.p.12
2. The European Union upgraded its direct access score to 5/5 after amending its Settlement Finality Directive to allow non-bank payment service providers direct access.p.11
3. The United States was downgraded to a 3/5 price transparency rating after the CFPB rescinded a circular that warned against deceptive marketing practices in remittance FX padding.p.12
4. Australia saw its price transparency rating downgraded to 1/5 as current ACCC guidance remains voluntary and fails to require disclosure of FX markups.p.12
5. India improved its price transparency score to 3/5 after the Reserve Bank of India issued a notification mandating invoice breakdowns of exchange rates and markups.p.12
6. Japan raised its price transparency score to 3/5 following confirmation from the FSA that its Principles for Customer-Oriented Business Conduct apply to cross-border remittances.p.12
7. Japan is positioned to upgrade its direct access score to 5/5 upon integrating its first non-bank payment service provider into the Zengin payment system in November 2025.p.11