G20 Roadmap for Enhancing Cross Border Payments: Scorecard report on direct access and price transparency (Wise)

Summary

• A total of eight G20 members achieved the highest 5/5 rating for direct access of non-bank payment service providers in 2025, including Brazil, China, Indonesia, Mexico, the Republic of Korea, Türkiye, the United Kingdom, and the European Union.p.10
• The European Union upgraded its direct access score from 4/5 in 2024 to 5/5 in 2025 following amendments to its Settlement Finality Directive.p.10
• The United Kingdom was the only market to achieve the highest 5/5 score for price transparency in 2025, upgrading from 3/5 following new FCA guidance.p.11
• The United States was downgraded on price transparency from 4/5 to 3/5 after the CFPB rescinded a circular on deceptive marketing practices, with US consumers projected to lose $19 billion to hidden FX markups in 2025.p.11
• Australia was downgraded from 2/5 to 1/5 on price transparency due to voluntary guidance, with Australian consumers projected to lose nearly $4 billion in hidden fees in 2025.p.11
• In Germany, direct access stands at 4/5* pending Eurosystem TARGET Guidelines, while price transparency remains at 4/5 as hidden FX markups by retail banks range up to 1.01% for Commerzbank and 0.46% for Deutsche Bank.p.18

Key insights

1. Former FSB Chair Klaas Knot stated that the G20 is currently not on track to achieve its 2027 targets for cross-border payments.p.2
2. As of August 2025, only 18 out of 27 EU Member States have transposed the required Settlement Finality Directive amendments into national law.p.14
3. US consumers are projected to lose $19 billion in obscured FX markups in 2025, which could rise to $46 billion by 2027.p.11
4. SIA xpate became the first non-bank payment service provider to gain direct payment system access in the EU via Bank of Latvia's system in April 2025.p.14
5. Several major German banks do not disclose exchange rates or fee structures during payment initiation, forcing customers to calculate fees on their own.p.18
6. The European Union's Payment Services Regulation is anticipated to be adopted in Q1 2026, which is expected to raise member state price transparency scores to 5/5.p.11