From Payconiq to Wero: Why payment consolidation is now a Board-level governance issue
- Linkvalue
- Jan 28
- 4 min read
What Boards of Payment and Electronic Money Institutions must understand as payments consolidate across Europe.
Payment consolidation has entered a new phase
2026 marks a pivotal year for payments in Luxembourg.
With the arrival of Wero, powered by the European Payments Initiative (EPI), Luxembourg’s retail banks are transitioning toward a pan-European account-to-account payment solution, with a mid-2026 rollout and a full Payconiq phase-out by September 2026.
Local payment schemes such as Payconiq, Paylib and iDEAL are progressively being unified into a shared European payment infrastructure for peer-to-peer and point-of-sale transactions. Similar transitions are underway across neighbouring markets, signalling a clear and deliberate European direction.
At first glance, this evolution may appear primarily technological. In practice, it reflects a structural shift in how payment activities are governed, supervised and overseen.
As payment infrastructures consolidate, accountability concentrates — and governance questions move decisively into the Boardroom.
When payments scale, governance concentrates
Payment systems were historically treated as operational infrastructure: reliable rails managed by IT, operations and external providers.
That assumption no longer holds.
Modern payment schemes such as Wero operate at scale, across borders and through shared infrastructures.
They introduce:
deeper interdependence between participants,
reliance on common technical and scheme-level governance frameworks,
shared operational, reputational and conduct risk
heightened supervisory attention at both national and European level.
As payments consolidate, the impact of failure expands. What once remained an internal incident can now trigger ecosystem-wide disruption, supervisory scrutiny and loss of trust.
This is the point at which payment innovation becomes a governance matter, not merely a product or technology decision.
What global payment systems reveal about the real risks
Europe is not the first region to experience large-scale payment consolidation. Other jurisdictions provide useful reference points for Boards.
India – UPI: scale exposes governance maturity: India’s Unified Payments Interface achieved rapid adoption and innovation, but also demonstrated that fraud prevention, resilience and participant accountability must be governed at scheme level, not only within individual institutions.
Brazil – Pix: resilience under systemic pressure: Pix transformed consumer behaviour almost overnight. Its success highlighted concentration risk and the need for continuous governance adaptation as fraud typologies and operational stress evolved.
United States – Zelle: when governance lags adoption: Zelle illustrates what happens when scale outpaces governance clarity. Public scrutiny around fraud and consumer protection quickly becomes a Board-level issue.
Singapore – PayNow: governance consolidation as a response: Singapore chose to consolidate scheme governance itself, strengthening accountability and resilience as payments became critical national infrastructure.
Across these examples, the lesson is consistent: when payment systems consolidate, governance must mature at the same pace — or faster.
What the Payconiq–Wero transition changes for Boards
The transition from Payconiq to Wero crystallises several oversight responsibilities for Boards of Payment Institutions (PIs) and Electronic Money Institutions (EMIs):
Scheme and strategic alignment: Participation in a European payment scheme is not merely commercial. Boards must understand how scheme rules, governance mechanisms and change processes align with the institution’s strategy and risk appetite.
Dependency and outsourcing risk: Shared rails increase reliance on external infrastructures, API hubs and intermediaries. Effective oversight goes beyond contracts to an understanding of critical dependencies, concentration risk and exit options.
Safeguarding and operational resilience: Higher transaction volumes and instant settlement intensify safeguarding, liquidity and continuity risk. These remain ultimate Board responsibilities, even when operational execution is delegated.
Data usage and accountability: Shared infrastructures generate complex data flows. Boards must understand roles and responsibilities across the ecosystem, including data protection, retention and accountability.
These are not technical questions. They are Board questions.
A short governance bridge: CSSF Circular 26/906
This evolution in payments aligns closely with the supervisory direction set out in CSSF Circular 26/906, which reinforces that governance must be proportionate to complexity, scale and systemic relevance. As discussed in our earlier regulatory update on Circular 26/906, supervisory focus is shifting away from formal structures toward effective Board oversight, collective accountability and informed judgement.
In consolidated payment ecosystems, this expectation becomes tangible through the annual compliance attestation, signed by the entire management body. It transforms governance from a process into a Board-level declaration. In payments, that declaration increasingly covers shared rails, third-party dependencies and customer outcomes.
Why this is a growth issue — not merely a compliance one
Payment consolidation is often framed as a growth opportunity. But weak governance in consolidated environments typically results in:
delayed supervisory approvals,
remediation under time pressure,
constrained innovation, or
erosion of partner and customer trust.
Conversely, Boards that combine payments expertise, regulatory literacy and independent challenge are better positioned to:
engage constructively with supervisors,
absorb regulatory change, and
scale payment solutions sustainably.
In this context, governance is not a brake on innovation. It is a condition for durable growth.
The role of independent Board oversight in modern payments
As payment infrastructures converge, the role of independent non-executive directors becomes more pronounced. Boards benefit from independent profiles who combine:
hands-on payment and scheme experience,
regulatory and compliance insight, and
an innovation mindset that understands scale, speed and dependency risk.
Independent oversight helps ensure that Boards can challenge assumptions, connect technical decisions to governance consequences, and sign off with confidence in fast-evolving payment environments.
Closing reflection — preparing Boards for the next phase of payments
The transition from Payconiq to Wero is not an isolated event. It is a visible marker of a broader shift in how payments are built, governed and supervised.
As payments become faster, more interconnected and more central to financial stability, governance concentrates — and Board accountability follows.
For Boards of payment and electronic money institutions, the question is no longer whether governance needs to adapt, but whether it is adapting fast enough to keep pace with modern payment realities.
Author perspective
This analysis reflects my experience serving on payment and fintech Boards and working with regulated institutions across the payments ecosystem, including during periods of product evolution, consolidation and supervisory engagement.
Through Linkvalue, I support Boards in strengthening governance, independent oversight and decision-making in regulated payment environments, where innovation, resilience and accountability must move together.
By Sonja Hilkhuijsen
Founder & Independent Non-Executive Director – Linkvalue
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