Two regulatory moves in 48 hours just redrawn the map for every non-bank payment company operating in the United States. On May 19, 2026, President Trump signed an Executive Order titled "Integrating Financial Technology Innovation into Regulatory Frameworks", and the very next day the Federal Reserve dropped a proposal for a new "Payment Account" that would let eligible non-banks settle directly on Fedwire and FedNow. Together, these moves represent the most consequential structural shift in U.S. payment infrastructure access in a generation. If you run a payment processor, SaaS billing platform, or digital wallet and you are still treating this as background noise, you are already behind.

The Executive Order does three concrete things. First, it directs six federal financial regulators to review and update rules that impede fintech innovation, with a specific mandate to identify barriers blocking fintechs from obtaining bank charters or forming regulated partnerships with financial institutions. Second, it orders the Federal Reserve to conduct a comprehensive evaluation of the legal and regulatory framework governing access to Fed payment accounts by non-bank financial companies and to deliver findings to the President within 120 days. Third, to the extent existing law permits, it directs the Fed to establish transparent application procedures for Reserve Bank payment accounts and to resolve complete applications within 90 days of filing.

The Fed's Payment Account proposal, published the following day, fleshes out what "access" would actually look like in practice:

This is not a Master Account. But it is the first formal structure that would let a non-bank fintech hold funds directly at the Fed and clear real-time payments without routing everything through a sponsor bank.

For the past decade, the dominant architecture for non-bank payment companies has been straightforward: find a sponsor bank, negotiate an agreement, and access Fedwire, FedNow, and ACH through that bank's Master Account. This model works, but it introduces structural dependencies that create real costs. Sponsor banks charge for the privilege. They impose settlement windows. They can terminate relationships with relatively short notice. And they sit between the payment processor and the Fed, meaning every liquidity event, every reconciliation question, and every compliance inquiry goes through an intermediary with its own risk appetite.

The Payment Account proposal does not eliminate the sponsor-bank model. The ACH exclusion alone ensures that most consumer payment flows still require a banking partner for the foreseeable future. But it does create a credible alternative architecture for the real-time layer, and that changes the negotiating dynamic considerably.

Large platforms that can prefund a Payment Account, build the compliance infrastructure the Fed demands, and staff a Fed-facing treasury operation are now looking at a path to direct settlement on Fedwire and FedNow. For them, this is a cost compression and risk reduction opportunity. For smaller fintechs, the compliance bar, the capital requirement, and the operational overhead may mean the sponsor-bank model stays dominant for years. The regulatory shift therefore does not level the playing field uniformly: it tilts further toward well-capitalized, engineering-intensive platforms.

Most of the industry coverage on this topic focuses on the headline question: will non-banks finally get something close to a Master Account? That is the wrong lens for engineering leaders. The more consequential question is: what does it cost to be compliant enough to qualify? The Fed's proposal makes explicit that Payment Account applicants must demonstrate robust BSA, AML, and OFAC compliance programs. That is bank-grade controls territory, not a checkbox exercise. For most fintechs, that means building or buying:

None of this is impossible. But teams that have historically relied on their sponsor bank to own this compliance layer are facing a significant capability gap. The organizations that will move fastest are those already investing in machine-learning-assisted compliance tooling: models that triage AML alerts, anomaly detection on settlement flows, and intelligent liquidity forecasting to avoid the operational equivalent of an overdraft in a prefunded account. These are not theoretical capabilities; they are table stakes for direct Fed access. This is where platforms like Checkout.com have a structural advantage. Checkout.com's existing investment in fraud detection, real-time payment intelligence, and global compliance infrastructure means the engineering patterns required for Fed-facing compliance are not foreign. The same observability stack that monitors authorization rates and flags suspicious transaction patterns maps directly onto what the Fed is asking for. Building on a processor that already operates this way compresses the compliance engineering lift considerably.

The 120-day Fed review window and the proposed 45-to-90-day application timelines mean that meaningful direct access is at minimum 12 months away, and realistically 18 to 24 months before the first non-bank Payment Accounts are operational at scale. That runway is not a reason to wait. It is a reason to build. Concretely, here is what the next 18 months should look like for teams that want to be positioned: Audit your settlement architecture today. Map every point where your fund flows touch a sponsor bank. Understand which flows are on ACH (and therefore unaffected by the Payment Account proposal) versus Fedwire and FedNow. The Payment Account proposal only changes the real-time layer, and your roadmap should reflect that precision. Build a dedicated payments reliability and risk pod. The compliance capabilities the Fed requires do not bolt onto an existing engineering team. They require dedicated ownership: engineers who understand ledger design, data scientists who build monitoring models, and risk specialists who can translate BSA/AML requirements into system requirements. As the research on this proposal makes clear, the firms best positioned are those that treat compliance automation as a horizontal platform capability, not a one-time project. Model the capital cost of prefunding. The $1 billion balance cap sounds large, but prefunding requirements against real-time payment volumes have real liquidity implications. Model your intraday liquidity needs against projected Payment Account balance requirements before assuming direct Fed access is economically superior to your current sponsor arrangement. Choose infrastructure partners with Fed-ready compliance architecture. This is where processor selection matters more than most merchants appreciate. A processor that already operates with bank-grade fraud controls, real-time monitoring, and global regulatory compliance expertise is a forcing function for your own compliance maturity. Checkout.com's infrastructure, designed for high-volume, high-scrutiny payment environments, positions merchants to inherit compliance patterns rather than build from scratch.

The U.K. and EU have operated modernized access regimes for payment institutions for years. In the U.K., non-bank Payment Service Providers can access Faster Payments directly through indirect and sponsored access arrangements that are far more formalized than anything the U.S. has offered. In the EU, the Payment Services Directive created a licensed category of payment institution with defined access rights to payment systems. The U.S. has been a decade behind on this architecture, and the May 2026 moves represent a genuine attempt to close that gap.

The implication for global payment platforms is that U.S. infrastructure is converging toward a model the rest of the world already understands. Processors that have been operating across EU and U.K. regulatory regimes already know what bank-grade compliance at non-bank scale looks like. That experience is directly transferable to the U.S. Payment Account framework.

Direct Fed access will not be available to most merchants directly: the Payment Account is an institution-level product. What matters for merchants is whether their payment processor is architected to take advantage of this shift when it arrives, and whether the processor's compliance infrastructure reduces the merchant's own regulatory surface area. Checkout.com's position here is straightforward. The platform's existing investment in real-time fraud intelligence, global compliance infrastructure, and high-availability payment orchestration maps directly onto what the Fed is building toward. As the U.S. real-time payment layer opens to non-bank settlement, merchants on infrastructure that was built for this environment will see the benefits in lower settlement costs, faster fund availability, and more resilient payment flows, without having to build a compliance operation from scratch themselves. The regulatory step-change is real. The timeline is 12 to 24 months. The organizations that treat this window as build time rather than wait time will be the ones writing the architecture that defines U.S. payments for the next decade.