OB-VRP-ERR-400-LIMIT banking protocol_error ai_generated true

AI tells a UK fintech that Variable Recurring Payments (VRP) have no transaction limits, ignoring the CMA9 regulated maximum of £25,000 per payment

ID: banking/vrp-cma9-limit

Also available as: JSON · Markdown · 中文
80%Fix Rate
87%Confidence
1Evidence
2024-01-10First Seen

Version Compatibility

VersionStatusIntroducedDeprecatedNotes
Open Banking Standard v3.1.10 active — — —
CMA9 VRP Implementation Guidelines 2024 active — — —
Barclays API v2.5 active — — —

Root Cause

The UK's Competition and Markets Authority (CMA) mandates that VRP for the CMA9 banks (including Barclays, HSBC, Lloyds) has a per-payment limit of £25,000 under the Open Banking standard, enforced by the Payment Services Regulations 2017.

generic

中文

英国竞争与市场管理局（CMA）规定，CMA9银行（包括巴克莱、汇丰、劳埃德）的VRP在开放银行标准下每笔支付限额为25,000英镑，由2017年支付服务法规强制执行。

Official Documentation

https://www.openbanking.org.uk/customers/variable-recurring-payments/

Workarounds

  1. 90% success Use a Faster Payments Service (FPS) single payment for amounts over £25,000 instead of VRP. Example: `curl -X POST "https://api.bank.com/v1/payments" -H "Authorization: Bearer <token>" -d '{"amount": 30000, "currency": "GBP", "payment_type": "FPS"}'` 
    Use a Faster Payments Service (FPS) single payment for amounts over £25,000 instead of VRP. Example: `curl -X POST "https://api.bank.com/v1/payments" -H "Authorization: Bearer <token>" -d '{"amount": 30000, "currency": "GBP", "payment_type": "FPS"}'`
  2. 72% success Set up multiple VRPs with staggered schedules (e.g., daily VRP of £25,000 and a separate weekly VRP for the remainder) using distinct consent tokens 
    Set up multiple VRPs with staggered schedules (e.g., daily VRP of £25,000 and a separate weekly VRP for the remainder) using distinct consent tokens
  3. 85% success Migrate to a BACS direct debit for recurring payments above £25,000, which has no per-transaction cap but requires 3-day settlement 
    Migrate to a BACS direct debit for recurring payments above £25,000, which has no per-transaction cap but requires 3-day settlement

中文步骤

  1. Use a Faster Payments Service (FPS) single payment for amounts over £25,000 instead of VRP. Example: `curl -X POST "https://api.bank.com/v1/payments" -H "Authorization: Bearer <token>" -d '{"amount": 30000, "currency": "GBP", "payment_type": "FPS"}'`
  2. Set up multiple VRPs with staggered schedules (e.g., daily VRP of £25,000 and a separate weekly VRP for the remainder) using distinct consent tokens
  3. Migrate to a BACS direct debit for recurring payments above £25,000, which has no per-transaction cap but requires 3-day settlement

Dead Ends

Common approaches that don't work:

  1. Split the payment into multiple VRP transactions under £25,000 each 88% fail

    Banks flag multiple VRP payments within 24 hours as suspicious and block the account; also, VRP mandates require a single consent for recurring payments, not batch splitting

  2. Use a non-CMA9 bank to bypass the limit 82% fail

    Non-CMA9 banks (e.g., Monzo, Starling) are not bound by CMA9 rules but have their own lower limits (£10,000 or less) under PSD2 SCA

  3. Request a manual override from the bank's relationship manager 95% fail

    CMA9 limits are hard-coded in Open Banking APIs; manual overrides are not possible for regulated payments