Information provided to members by OGR.

As Congress enters its final legislative week of 2025, lawmakers are racing to close out a crowded agenda before adjourning for the holiday recess. While progress is being made on several fronts, major questions around government funding and health care policy are likely to spill into the new year.

Following the Thanksgiving break, Congress returned to Washington with four core priorities: government funding, the National Defense Authorization Act (NDAA), Affordable Care Act (ACA) subsidy extensions, and a package of executive branch nominations. Of those, the NDAA is on track for final Senate approval, and a broad nominations package is expected to clear later this week. Efforts to advance FY 2026 appropriations, however, remain stalled, with negotiations over top-line funding levels continuing behind the scenes. As a result, meaningful action on government funding is now expected in January.

Health care has emerged as the most significant unresolved issue of the year. The Senate failed to advance an ACA subsidy extension, and a complex House deal aimed at broader reform collapsed over the weekend. The setback highlights ongoing challenges for Republican leadership as they attempt to balance moderate demands with resistance from conservative members, particularly in the absence of clear policy direction from the White House.

At the same time, the administration remains focused on pressing global and domestic matters. Foreign policy challenges, including the war in Ukraine and rising tensions involving Venezuela, continue to command attention. Federal agencies are also working through implementation rules for the recently passed reconciliation bill, while the Office of Management and Budget moves forward with preparations for the President’s FY 2027 budget, expected in February.

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Each week, members receive a full version of this report. To receive that and more, join the Innovative Payments Association to stay informed on the decisions shaping the future of payments.

By Brian Tate, President and CEO, Innovative Payments Association

As we enter 2026, the payments industry is confronting a convergence of regulatory, technological, and political forces that will reshape how financial services operate in the U.S. These shifts are not theoretical – they are underway, and demand clarity, planning, and leadership. Innovation continues at a rapid pace, but the external environment has become increasingly difficult to interpret. For companies across our sector, this creates both challenges that require attention and opportunities that call for strategic action.

Below are five developments that are likely to influence how our industry operates and serves consumers in the year ahead.

1. AI Will Move from Experimentation to Everyday Infrastructure

Artificial intelligence is no longer an emerging technology – it is becoming integral to how financial institutions manage risk, detect fraud, and support customers. In 2026, more providers will transition AI applications from pilot programs to operational systems.

Performance gains make this shift unavoidable. Early adopters are already seeing significant improvements in fraud detection and pattern recognition compared to traditional tools. For a sector built on security and trust, AI is quickly becoming indispensable.

The challenge is not adoption – it is navigating uncertainty. Companies want to deploy AI responsibly, yet many are waiting for clearer regulatory expectations. Policymakers and industry participants will need to work together to establish guardrails that enable innovation without introducing unnecessary risk. The goal is clarity, not constraint.

2. Open Banking Will Shift Competitive Expectations

Open banking is no longer a distant possibility. The CFPB is working on updating the Personal Financial Data Rights rule that will fundamentally reshape how consumers access, use, and share their financial information.

With greater data portability, consumers will have more choice and more transparency. Providers, in turn, will face new competitive pressures as customers gain the ability to compare products and move between services with unprecedented ease.

One of the IPA’s priorities going forward is ensuring that the final rule takes into account all the players in the ecosystem and gives them a level playing field.

This transition requires significant investment in data infrastructure, cybersecurity, and governance. But the institutions that treat open banking as a strategic opportunity – not merely a regulatory obligation – will gain an advantage in a more dynamic, consumer-driven marketplace.

3. Stablecoins Are Moving from Concept to Utility

Stablecoins continue to expand in relevance, even amid a volatile policy environment. Market analysts project substantial growth over the next several years, driven by real use cases in cross-border payments and institutional settlement.

International regulatory developments are accelerating adoption. Europe’s Markets in Crypto-Assets (MiCA) framework has provided a clearer path forward, and global firms are responding.

The Genius Act has put the United States on a path towards a regulatory structure for stablecoins. The passage of the law is only the first step. Next up are the regulators who will need to make the rules of the road. The IPA plans to weigh in on behalf of our members’  interests. The nexus of digital assets and payments will be the gateway to unleashing the full potential of stablecoins.
 
4. The 2026 Elections Will Influence Policy Decisions

Election cycles always introduce uncertainty, but 2026 carries particular weight. With control of the House in question, agencies and lawmakers may adjust timelines, priorities, and policy strategies throughout the year.

Some agencies may accelerate outstanding initiatives in anticipation of political change. Others may slow activity to avoid committing to policies that could face immediate revision.

For the payments industry, this means flexibility is essential. Forward-looking companies will stay engaged, monitor developments closely, and remain prepared for multiple policy scenarios. In an environment without clear signals, consistent dialogue with policymakers across the spectrum becomes even more critical.

5. The CFPB Is Poised to Increase Its Supervisory Activity

Although the future of the Consumer Financial Protection Bureau remains uncertain, the prudential regulators, collectively, will continue to engage in more active oversight.

Providers, from big tech to major platforms, expect heightened scrutiny across compliance programs, product design, and operational practices. In this environment, transparency, strong documentation, and proactive engagement with regulators are not optional – they are foundational to sustainable operations and strategic risk management.

An Environment Without Clear Signals

Finally, the payments industry is operating in one of the most complex environments in recent years. Technological change is accelerating. Regulatory expectations are evolving. Political dynamics are shifting. Traditional indicators no longer offer reliable guidance for what comes next.

Yet, even amid this uncertainty, we are confident in our industry's resilience. The payments sector has consistently demonstrated the ability to innovate responsibly while protecting consumers and supporting the broader financial ecosystem. We have weathered regulatory shifts, economic cycles, and technological disruptions before, and we will do so again.
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At the Innovative Payments Association, our priority is to ensure that members have the insights, tools, and representation needed to operate effectively in this climate. The year ahead will challenge us, but it will also bring meaningful opportunities to strengthen the financial tools that millions of Americans rely on every day.
Our industry is prepared for this moment – and ready to lead.

At today’s meeting of the Consumer Financial Protection Bureau’s Consumer Advisory Board, Innovative Payments Association President and CEO Brian Tate delivered a clear message: workers need safe, affordable access to wages they have already earned — and regulators must restore clarity to support that access.

The testimony arrives at a pivotal moment. Millions of Americans continue to face a simple but profound financial challenge: the timing of their expenses rarely aligns with the timing of their paychecks. As Tate noted, this gap makes liquidity essential, particularly for the growing number of workers living close to their financial margins.

Why Earned Wage Access Matters

One of the most effective tools available to help bridge these gaps is earned wage access (EWA). Tate underscored a point too often lost in policy debates: EWA is not credit. It does not involve underwriting, does not create debt, and does not obligate repayment if a worker leaves their job. Instead, it provides timely access to wages that workers have already earned — a straightforward concept with meaningful impact.

Research backs this up. Studies from Harvard and the Federal Reserve show that EWA programs deliver lower-cost alternatives to payday loans, reduce reliance on high-cost financial services, and support workers facing unexpected expenses. As Tate emphasized, these programs are particularly relevant as the nature of work changes. In an economy where pay speed increasingly drives worker loyalty, EWA has become a practical, modern financial tool.

Regulatory Clarity Is the Missing Piece

For nearly a decade, federal policymakers across administrations have recognized that properly structured EWA products are distinct from traditional credit. The CFPB’s 2017 Payday Lending Rule and its 2020 Advisory Opinion both affirmed this distinction and provided a roadmap for innovation.

The Bureau’s more recent interpretive proposal, however, introduced significant uncertainty by attempting to treat EWA like credit. Tate made clear that this reversal conflicts with established precedent and risks undermining a product that workers and employers increasingly rely upon.

To restore stability, Tate called on the CFPB to issue a new Advisory Opinion that reflects how the EWA market has evolved. Such an opinion should reaffirm the non-credit nature of EWA, provide an optional safe harbor for providers, and allow continued innovation in alignment with the Administration’s broader policy goals—including those outlined in Executive Order 14192.

A Path Forward That Supports Workers

Tate’s remarks highlighted a simple principle: when workers have already earned their money, accessing it should not be complicated or costly. Regulatory clarity is essential to maintaining that reality. A consistent, straightforward framework would protect consumers, give providers predictable guardrails, and enable employers to offer a benefit that supports financial stability.

The full testimony offers a deeper examination of the data, regulatory history, and policy recommendations that shaped today’s discussion.

Information provided to members by OGR.

As both chambers of Congress reconvene this week, lawmakers are attempting to close out the year with substantive legislative progress. Yet significant internal divisions, competing priorities, and a compressed calendar continue to shape what can realistically be achieved before the holiday recess.

Healthcare will be the central political flashpoint. Enhanced Affordable Care Act (ACA) tax credit subsidies are scheduled to expire at year’s end, placing pressure on Senate Democrats to advance a three-year extension. They plan to force a vote this week, even as Republicans remain divided over whether to offer a conference-wide alternative. With no agreement in sight, this issue is expected to carry over into January, when negotiations may resume under heightened urgency.

Defense policy is also moving toward resolution. House leaders released the final compromise version of the National Defense Authorization Act (NDAA) on Sunday evening, positioning the bill for a House vote this week and Senate action to follow. While the core defense provisions enjoyed bipartisan, bicameral support throughout the year, final negotiations extended into December as lawmakers sparred over unrelated issues, including housing initiatives and artificial intelligence regulation. Despite these tensions, the NDAA is expected to pass with commanding majorities in both chambers.

Political considerations, including the 2026 election cycle, are increasingly influencing the environment on Capitol Hill. Texas—home to one of the nation’s most consequential delegations—closes its candidate filing deadline today. A wave of retirements and recent court decisions will reshape numerous districts, adding additional complexity to next year’s legislative dynamics.

Taken together, these pressures underscore the stakes of the weeks ahead. These final days of the session will determine whether Congress can deliver year-end legislative wins—or whether key debates will be deferred to 2026.​

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Each week, members receive a full version of this report. To receive that and more, join the Innovative Payments Association to stay informed on the decisions shaping the future of payments.

Information provided to members by OGR.

Congress is back in Washington for a three-week sprint to close out the year, and while the agenda is packed, lawmakers return without the immediate pressure of a funding deadline. For the second year in a row, the threat of a holiday shutdown has been averted.

The National Defense Authorization Act (NDAA) remains the marquee item expected to reach the President’s desk before year-end. Yet major policy questions still hang over the bill, including a contentious debate over whether Congress should preempt state authority on artificial intelligence. At the same time, appropriators in both chambers are working to translate the recent continuing resolution into longer-term spending progress. Negotiations on additional minibus packages continue, but significant gaps remain on topline spending levels and key policy riders. A larger funding deal is possible — but only under extraordinary circumstances.

Health care will once again command attention. A required vote on Affordable Care Act premium subsidies is scheduled for December 12, but absent a bipartisan agreement, it is widely expected to fail along party lines. The White House’s proposal for a two-year extension with new caps and minimum premiums has not gained traction with congressional Republicans.

Outside the legislative arena, recent events are reshaping the Administration’s priorities. The shooting of National Guard troops in Washington last week has triggered renewed focus on tightening immigration and asylum policies. Meanwhile, an early-December relief plan for farmers affected by ongoing tariff disputes is expected, even as Washington awaits a potential Supreme Court ruling on the Administration’s tariff authority — a decision that could carry significant implications for trade policy.

Do not miss out.
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Each week, members receive a full version of this report. To receive that and more, join the Innovative Payments Association to stay informed on the decisions shaping the future of payments.