The Bank Opened CHAPS to Non-Banks in 2017. The First One Arrived This Week.

Modulr said on 19 August that it had become a direct participant in CHAPS, and made a larger claim alongside it: that it is now the only non-bank payment service provider in the UK with direct access to all three of the country's main sterling payment schemes.

The claim is checkable, because the Bank of England and Pay.UK both publish their participant lists. We checked it. It holds, and the margin is wider than the phrasing suggests.

Fifteen reach one scheme, two reach two, one reaches three

Pay.UK's published list of Faster Payments direct participants contains 47 names. Fifteen of them are non-bank payment service providers — firms authorised by the Financial Conduct Authority as electronic money institutions or payment institutions rather than as deposit-taking banks. Among them are Wise, Stripe UK, Square, SumUp, Soldo, Ebury, Equals Money, Corpay, PPS and Modulr.

Of those fifteen, two also appear on Pay.UK's Bacs list: Modulr and PayrNet. Of those two, one appears on the Bank of England's CHAPS list. It is Modulr.

The full three-scheme overlap — institutions of any kind that are direct participants in Faster Payments, Bacs and CHAPS simultaneously — is thirteen. Twelve are banks or a building society. The thirteenth is Modulr.

The door was opened in 2017

This was not a door that opened last week. On 19 July 2017 the Bank of England announced that non-bank payment service providers could apply for a settlement account in its Real-Time Gross Settlement system. In a news release the following April the Bank described what that change enabled: direct access, for the first time, to the UK payment schemes that settle in central bank money — and it named them, "including Faster Payments, Bacs, CHAPS, LINK, Visa, and the new digital cheque imaging system."

CHAPS was on the list from the beginning. It took nine years for a non-bank to appear on the CHAPS register.

The first non-bank to use the new route did so on 13 April 2018, when TransferWise — now Wise — became a direct participant in Faster Payments. The Bank called it "an important milestone in its work to facilitate greater innovation and competition in the payments industry."

Wise is still on one scheme

Eight years and four months later, Wise appears on Pay.UK's Faster Payments list and on neither of the other two. It is not a Bacs direct participant and it is not a CHAPS direct participant. Neither are Stripe, Square, SumUp, Soldo, Ebury, Corpay, CreDec, Equals Money, PPS or Prepaid Financial Services.

That is not a judgement about any of them. Direct participation is a cost and an operational obligation, and firms that route international transfers or card acquiring have less reason to want a sterling high-value rail than a firm that runs payroll. It does mean the 2017 reform has produced a much narrower result at the CHAPS end than at the Faster Payments end.

One of thirty-five

The Bank's CHAPS page, last updated on 17 August 2026, lists thirty-five direct participants. Twenty-nine are banks or a building society. Four are financial market infrastructures — CLS Bank International, Euroclear Bank, Fnality UK and LCH. One is the Bank of England itself. One is Modulr.

The list moves rarely. Internet Archive captures of the same page show thirty-three names in June 2025, still thirty-three in January 2026, still thirty-three in April 2026, and thirty-four by 10 June 2026, when Banking Circle had been added. Modulr took it to thirty-five. Two additions in fourteen months.

Why the queue is short

The Bank's access policy for RTGS settlement accounts, published in April 2025 and last updated on 30 January 2026, sets out a structural asymmetry that helps explain the shape of the funnel.

Authorised electronic money institutions and authorised payment institutions can hold a settlement account in RTGS, and a prefunding account where relevant. They cannot hold a reserves account, because they are ineligible to participate in the Sterling Monetary Framework. The policy's own table sets the remuneration on a reserves account at Bank Rate and on a settlement-only account at nothing.

A bank that becomes a CHAPS direct participant earns Bank Rate on the balances it holds at the Bank of England. A non-bank that becomes a CHAPS direct participant earns nothing on the balances it must hold there, and must additionally keep separate accounts to segregate its own funds from client funds. Direct access to central bank settlement is available to non-banks on terms that are not the same terms.

CHAPS is less exotic than "high-value" makes it sound

CHAPS is usually introduced as the UK's high-value system, which is accurate in aggregate and misleading about the individual payment. The Bank's own statistics for 2025 put the average CHAPS payment at £1.8 million and the median at £4,586. Ninety-four per cent of CHAPS payments were for £1 million or less.

The aggregate figures are what earn the description: CHAPS accounts for 0.4% of UK payment volumes but 91% of total sterling payment values, and settles the equivalent of annual UK GDP every nine working days. Financial institution payments were 24% of payments but 73% of value.

For a platform whose stated business is payroll, supplier payments and collections, the median matters more than the mean. A same-day, irrevocable, central-bank-settled rail with a median payment under £5,000 is not an exotic wholesale facility. It is a faster way to move ordinary business money on a deadline.

The company's numbers check out

Modulr's release cites the Bank of England for CHAPS settling £93.9 trillion across a record 53.3 million payments in 2025, an average of £371.3 billion every working day. The Bank's published figures give a 2025 daily average of £371,332 million and 210,483 payments, and its own commentary states that 2025 volumes grew 1.1% to a record 53.3 million and value grew 7.3% to £93.9 trillion. The figures match.

Myles Stephenson, Modulr's founder and chief executive, said the firm is "now the only non-bank payment service provider in the UK connected directly to all three major UK payment schemes." Modulr is authorised as an electronic money institution by the FCA in the UK and by De Nederlandsche Bank in Europe, and says it processes more than 200 million transactions and over £180 billion in payment value on an annualised basis for more than 6,000 businesses.

What is established and what is not

Established: Modulr announced CHAPS direct participation on 19 August 2026. The Bank of England's CHAPS list, last updated 17 August 2026, contains thirty-five names including Modulr FS Limited. Pay.UK's lists place Modulr in both Faster Payments and Bacs. No other non-bank payment service provider appears on all three. The Bank opened RTGS settlement accounts to non-bank PSPs in July 2017, naming CHAPS among the schemes affected, and the first non-bank joined Faster Payments in April 2018. Non-bank participants hold unremunerated settlement-only accounts and cannot hold reserves. The CHAPS figures in Modulr's release match the Bank's published statistics.

Not established: the exact date Modulr was added to the Bank's register, which we can bound only to between 8 June and 17 August 2026 from archived captures; whether Pay.UK's lists were current on the day we read them, since they carry no visible revision date; and whether any further non-bank has an application in progress at any of the three schemes, which none of the three operators publishes. The classification of each name as bank or non-bank is ours, based on whether the entity holds a UK deposit-taking licence — Adyen, ClearBank, LHV, Banking Circle, The Bank of London, Zempler and Tesco Bank are banks on that test and are excluded from the count of fifteen, and a different test would give a different number.

The narrow reading is that a policy written in 2017 to let non-banks settle in central bank money has, nine years on, produced fifteen non-banks on the retail rail, two on the direct debit rail, and one on all three.