2 PAYMENT METHOD PROFILES: PAY BY BANK
Merchant Cost Considerations The median costs for ACH transactions in the United States, including both initiating and receiving payments, range between $0.26 and $0.50 USD. 467 SEPA Direct Debit transactions in Europe typically cost between €0.05 and €0.20. 468 In the United Kingdom, BACS transaction costs generally range from £0.05 to £0.50. 469 Bank transfer costs can be impacted when a third-party provider is providing pay-by-bank services to merchants as seen in geographies where bank transfers for the consumer-to-business use case are not ubiquitous or government mandated such as in Europe or India. Cost Of Bank Transfer Analysis 470
Payment Method Largest Market
Estimated Pricing Estimated Volume Estimated Implied Merchant Fees
SEPA Direct Debit
European Union
1.14%
$1,000,000,000,000 $11,378,000,000 $187,490,000,000 $3,271,700,500 $2,491,480,000,000 $19,931,840,000
BACS
United Kingdom 1.75%
ACH
United States
0.80%
TOTAL
0.94% $3,678,970,000,000 $34,581,540,500
Table 2.15
Merchants will not typically engage directly with bank transfer payment methods such as ACH, BACS and SEPA Direct Debit. Instead, it is more common merchants accept them via full-stack processors such as Adyen, PayPal and Stripe, who will take wholesale pricing from the bank transfer companies and add their own mark- ups. As a result, when looking at pricing for bank transfer, we have taken publicly-available default pricing from the websites of these three full-stack processors. This is likely to over-estimate bank transfer fees as larger merchants may be able to negotiate acceptance pricing for bank transfer transactions below these default fees. The data we have collected on ACH, BACS and SEPA Direct Debit implies a negative correlation between size and fees, suggesting economies of scale are passed on to the user in terms of lower pricing. Regulation Recent regulatory activity in the United States includes the CFPB filing a motion to stay in July 2025 regarding its Open Banking Rule 1033 which had been previously been suspended in May 2025 by the Bureau. 471 The rule originally aimed to set guidelines for consumer financial data access for third-party service financial providers and increase consumer control of their data to facilitate an open banking environment in the U.S. and greater prevalence of pay by bank solutions in the U.S. The rule was rescinded in May 2025 with the Bureau stating, “...Bureau leadership has determined that the rule is unlawful and should be set aside.” 472 In July 2025, the CFPB published a Motion to Stay where it notes, “...the Bureau has now decided to initiate a new rule-making to reconsider the rule with a view to substantially revising it and providing robust justification.” 473
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