July 07, 2025

Pay-by-Bank and the Merchant Payments Use Case: Benefits, risks and potential impacts on consumer payment behaviors in the U.S.

Byoung Hwa Hwang¹

Introduction

The consumer payments landscape is rapidly evolving. In the United States, the growth of instant payments and innovations such as open banking are among the many developments shaping today's consumer payment behaviors.²

In this dynamic environment, "Pay-by-Bank" is an emerging payment solution gaining traction. Also known as "account-to-account" or "bank-based payments," it enables the direct transfer of funds from a payer's bank account into the account of a payee.³ By offering merchants an arguably cost-efficient and secure alternative to current payment methods such as cash and cards, Pay-by-Bank could be appealing for the merchant payments use case.⁴

This note aims to enhance our understanding of Pay-by-Bank and explores its potential to be adopted at the point of sale (POS). Section 1 outlines recent consumer payment trends in the U.S.; Section 2 describes Pay-by-Bank and illustrates its usage at the POS; Section 3 explores potential benefits, risks and opportunities for Pay-by-Bank as a merchant payment method; finally, Section 4 highlights key findings and proposes areas for further research and analysis.

Section 1: Overview of recent consumer payment trends in the U.S.

The use of cash and checks for consumer payments is continuously declining. The 2024 Diary of Consumer Payment Choice (DCPC) finds that in recent years, the use of cash for consumer payments has been steadily declining and seemingly reached a "floor."⁵ Similarly, data from the 2021 Federal Reserve Payments Study points to a continuous decline in the number of consumer checks being used.⁶

At the same time, ACH-, cards- and alternative nonbank payments are on the rise. Studies point to a substantial increase in ACH transfers and debit- and credit card payments—both by number and value.^7,8 In addition, ownership and usage of alternative payment methods such as digital wallets and peer-to-peer payment apps are growing.⁹

Currently, retail payment transactions are dominated by cards. According to the 2023 Survey of Consumer Payment Choice (SCPC), credit cards are the most frequently used payment method by number for retail purchases (32 percent), followed by debit cards (30 percent) and cash (19 percent).¹⁰ Similarly, the 2024 DCPC study finds that credit cards account for approximately 32 percent, debit cards for 30 percent, and cash for 16 percent of payments by study participants.¹¹

A factor of note may be that the cited studies point to differences in payment behavior depending on income, race, ethnicity, and age of the payer, as well as transaction types. For example, cash is more frequently used by individuals aged 55 years and older and by low-income households; cards are the most prominent payment method for remote payments.¹²

Cards are also the dominant funding method for digital wallets and payment apps. Customers initiating payments through digital payment solutions can generally choose their preferred funding method. Javelin Strategy's 2023 North American Payments Insights study finds that the majority of users (65 percent) fund their digital wallets with debit cards, followed by credit cards (53 percent), and about one quarter of consumers directly link their bank account to fund digital wallet transactions (26 percent).¹³ An increase in usage of digital wallets and payment apps for consumer payments is thus linked to the growing card transaction volumes referenced above.

The shift towards digital payments will likely continue. While the shift toward non-cash payments was accelerated by social distancing rules during the COVID-19 pandemic, studies such as the 2024 DCPC suggest that the pandemic had lasting effects on advancing the move towards digital consumer payments.¹⁴ As new technologies and payment innovations continue to emerge, this trend is expected to prevail.

Section 2. Pay-by-Bank and the merchant payments use case

Pay-by-Bank offers an alternative to payments intermediated through card networks. In this note, Pay-by-Bank is defined as transactions originating from a customer's bank account, routed over ACH- or instant payment rails, and settled directly into the bank account of a merchant. This is different from payment methods such as cards, in which payments between an issuing bank (that is, a customer's bank account) and acquiring bank (that is, a merchant's bank account) are authorized, cleared, and settled via card network intermediaries.¹⁵

Pay-by-Bank relies on open banking infrastructure and is facilitated by third-party service providers performing key technical and payment processing functions. The BIS Report on open banking and application programming interfaces (APIs) describes open banking as "the sharing and leveraging of customer-permissioned data from banks with third-party developers and firms to build applications and services to provide more efficient and transparent options in banking."¹⁶

In the context of Pay-by-Bank, third-party service providers support critical payment initiation, user authentication, consent authorization, and processing functions, among others. To provide these services, third parties commonly establish connections with merchants, sending banks, and receiving banks in the form of APIs.¹⁷ For example, with the consent of customers, third-party providers use open banking APIs to establish connections with customers' banks to access financial information, including customer account and funds availability information, to facilitate payment initiation and authorization processes.

A typical Pay-by-Bank payment flow may look as follows.¹⁸ During checkout at a merchant, customers select Pay-by-Bank as a payment option and are prompted to choose their primary bank from a list of participating institutions. The choice redirects customers to their bank's website or mobile banking app to log in to their account with their username and password or with biometric identifiers. During this step, customers may be asked to consent to a third-party provider accessing their bank account details through an API. Of note, open banking APIs do not require customers to share their bank login information with third-party service providers. Rather, sensitive login credentials stay between customers and their banks.¹⁹

The account authentication and identity verification steps may involve switching between screens or even devices. For added security, customers could be asked to enter a one-time code displayed on the merchant's website or sent to them via SMS or app into their banking interface.

Upon successful authentication, customers proceed with authorizing their purchase by confirming the specified payment amount and payee (that is, merchant) details. In the back end, sending banks and receiving banks engage in approval, clearing, and settlement processes, whereby customers' funds availability is checked, transactions are approved, respective accounts are debited and credited, and payment confirmation notifications are sent to the customer and merchant.

The current use of Pay-by-Bank for consumer payments is generally low, but adoption is growing. Findings from a 2024 study on Consumer Sentiment About Open Banking Payments indicate that the overall uptake of Pay-by-Bank remains limited; about 11 percent of U.S. adults have conducted at least one open banking payment transaction in the past year.²⁰

At the same time, the study points to a higher willingness to use open banking payments among younger respondents (72 percent of Gen Z and 66 percent of millennials) and higher income earners (consumers earning at least $100,000 per year), suggesting potential for future adoption among these groups.²¹

In addition, the 2023 SCPC points to a continuous increase in bank account-to-account payments, suggesting an upward trajectory for this payment method.²²

Pay-by-Bank could gain momentum as more deployments use instant payment rails. While at present, most Pay-by-Bank solutions settle transactions over ACH, forthcoming deployments may increasingly make use of instant payment rails.²³

For example, retailer Walmart – in partnership with technology firm Fiserv – plans to offer an instant Pay-by-Bank solution for both online and in person purchases at the retailer. Starting in 2025, customers can link their bank account details to their Walmart accounts to fund instant payment transactions. By bypassing card networks, the merchant could save on interchange fees and benefit from faster funds availability of payments routed over instant payment rails (see Section 3 for a more detailed discussion of potential cost benefits).²⁴

Similarly, Visa acquired open banking firm Tink to develop its own instant Pay-by-Bank solution for the U.S. market.²⁵ In addition, existing Pay-by-Bank solutions may expand their settlement rails beyond ACH and offer customers the option for instant settlement.

Section 3. Benefits, risks and opportunities of Pay-by-Bank for the merchant payments use case

1. The cost argument

From the merchant perspective

Pay-by-Bank is often presented as a cheaper payment acceptance method for merchants—particularly in comparison to credit cards. By reducing or eliminating various fees—mainly interchange fees— merchant customers adopting Pay-by-Bank for POS payments could save significantly; according to some estimates, Pay-by-Bank could result in cost savings between 40 up to 85 percent compared to credit cards.²⁶ ­

However, such cost saving estimates should be approached with caution. As noted, Pay-by-Bank solutions, too, involve several entities and services that will translate into fees charged to merchants. For example, merchants may incur initial setup and integration fees, as well as ongoing payment transaction, processor, and subscription fees charged by third-party providers. In addition, merchants' receiving banks may apply additional transaction and service fees.

Of note, ACH- and instant payment operators charge participating financial institutions a per transaction fee for processing payments, while card interchange fees are typically charged as a percentage of the transaction amount.²⁷ As such, total merchant fee amounts will vary depending on the transaction types and their values and volumes. In addition, some Pay-by-Bank providers offer their merchant customers different pricing models, depending on their usage and services utilized.

Taking these variations into account, a blanket claim of significant cost savings resulting from merchants switching to Pay-by-Bank at the POS should be interpreted with care. While Pay-by-Bank may well present a cheaper payment acceptance method than credit cards, further analysis is needed to make a more precise and direct cost comparison across different payment channels.

From the bank perspective

Pay-by-Bank could present an opportunity for banks to compete with nonbank payment providers and to retain customer relationships. Pay-by-Bank could be instrumental in diversifying banks' existing financial services offerings—including their payment services. By offering their customers new payment solutions, banks could compete with emerging nonbank payment providers and avert customers from depositing account balances into nonbank accounts. In addition, fees charged for Pay-by-Bank transactions may present new revenue streams for banks and alleviate them from passing on profits from their card business in the form of customer reward programs.²⁸

However, an uptake of Pay-by-Bank transactions could harm credit card banks' business models. Some banks generate significant revenue from their card businesses, especially from their credit card operations.²⁹ For example, credit card banks benefit from various charges and fees pertaining to interest, interchange, late payments, foreign exchange, and annual fees, among others.³⁰ Depending on the uptake and usage of Pay-by-Bank and resulting impacts on existing bank-offered payment methods, banks could see adverse effects on their card business revenues.

In addition, banks incur a range of development and integration costs related to establishing and maintaining open API connections for Pay-by-Bank payments, including technical infrastructure, security and compliance costs. What's more, banks currently do not charge third-party service providers for access to customer financial data.³¹ Allowing third parties to access customer financial data may hamper banks' competitive advantage of developing personalized financial products to their clients and could risk eroding—rather than maintaining—customer relationships.

Further research could study the impact of Pay-by-Bank on other payment methods and explore potential questions including: How many customers switch from debit- or credit cards to Pay-by-Bank solutions? Are different payment methods used complementarily or at the expense of one another? Do customers adopt Pay-by-Bank offered by the same card issuing bank or do they switch to another bank? Exploring these questions could aid banks in more accurately assessing the profitability and potential tradeoffs of offering Pay-by-Bank solutions.

From the customer perspective

Pay-by-Bank transactions are typically free for customers. Looking at current deployments, customers do not pay any explicit Pay-by-Bank usage fees, as charges are likely woven into existing bank account maintenance fees.³² In comparison, credit cards, for example, can come with significant annual service fees.

However, the absence of explicit customer usage fees may not be as compelling as current spending rewards offered by credit cards. Despite the absence of direct Pay-by-Bank usage fees, customers may be attached to alternative payment methods—most notably credit cards—because of the myriads of spending rewards they offer. Rewards range from cash back on eligible purchases or at select merchants, points that can be redeemed for travel, retail purchases, and gift cards to incentives such as loyalty status at select hotels and airlines, airport lounge access, and rental car and travel insurance coverage, among many others.³³

To compete with these incentives, Pay-by-Bank promotions may need to be comparable to, if not more generous than those already on offer. To rival existing offers, merchants could pass on savings from lower Pay-by-Bank fees to their customers in the form of discounts. However, such incentives may affect merchants' own cost-benefit calculations and their adoption of Pay-by-Bank solutions.

In addition, customers may be enticed by access to credit to fund their purchases. Credit cards may be appealing because they allow customers to spend funds beyond available account balances (that is, customers borrow money from card issuing banks up to a set credit limit and with interest if a balance is carried over). The extension of credit allows customers to make purchases immediately, giving them greater autonomy and flexibility to spend and pay off balances at their convenience.

Pay-by-Bank could alleviate consumer debt resulting from credit purchases. While Pay-by-Bank might in some instances allow customers to transact beyond available account balances (for example, if a transaction is routed over ACH and the customer's bank allows for overdrafts), most transactions validate funds availability prior to authorizing a payment, rejecting those with insufficient balances.

Spending beyond available account balances introduces risks including debt accumulation, high interest and late payment fees, and damages to customer credit scores. Data from the Federal Reserve Bank of New York's Quarterly Report on Household Debt and Credit reveals that in Q4 of 2024, total household debt increased by $93 billion (0.5 percent) to a total of $18.04 trillion. Specifically, credit card balances increased by $45 billion to a total of $1.21 trillion and delinquency transition rates into serious delinquency (defined as 90 days or more past due) increased about 7 percent.³⁴ Enticing customers to switch to non-credit payment methods such as Pay-by-Bank could arguably reduce such debt burdens.

In conclusion, the cost savings argument of Pay-by-Bank is not straightforward for merchants, banks, or customers and comes with both opportunities and drawbacks.

2. The safety argument

Potential benefits

Several Pay-by-Bank product features may provide greater safety and security than alternative forms of payment. Pay-by-Bank incorporates certain product design features that could improve its resistance to various payment risks: The payment initiation process of Pay-by-Bank transactions often involves enhanced security controls such as two- or multi-factor authentication to verify customers' identity before a payment can be authorized. Criminals will find it more difficult to spoof biometric identifications and retrieve a one-time security code than to make purchases with a lost or stolen debit- or credit card, or a compromised PIN, for example.³⁵

These features may protect customers from fraud and reduce merchants' exposure to subsequent payment disputes and reversals initiated by affected consumers. They could also reduce merchants' vulnerability to sham disputes whereby merchants themselves fall victim to claims against legitimate transactions, resulting in merchants having to issue a refund.³⁶

In addition, the direct bank-to-bank interaction of Pay-by-Bank transactions may reduce the exposure to operational outages and potential points of failure that multi-step, multi-party clearing and settlement arrangements may face.

As a bank-offered payment solution, Pay-by-Bank deployments could also benefit from the brand recognition and established reputation of their providing banks, and be perceived as more trustworthy, resilient and safe than nonbank alternatives, for example.³⁷

Despite these varying features, Pay-by-Bank introduces a range of new safety risks that need to be carefully considered.

Potential risks

Consumer trust may not extend to open banking payment solutions. Despite customers expressing greater trust in financial products offered by established and larger banks than in those offered by nonbanks, studies such as the 2024 Consumer Sentiment About Open Banking Payments suggest that many individuals remain skeptical about open banking payments: More than half of the surveyed individuals (56 percent) cite security and trust concerns as their top reasons for not using open banking payments.³⁸

Such wariness may stem from the direct customer interaction with novel and unfamiliar third-party service providers during customer identification and account authentication processes, for example, which could raise data privacy concerns.³⁹

Pay-by-Bank is not immune to rising payment fraud. According to 2023 data published by the FTC Consumer Sentinel Network, fraud has increased across all payment methods since the COVID-19 pandemic: Payments conducted using credit-, debit- and prepaid cards and payment apps experience the highest number of fraud reports; bank transfers and cryptocurrency payments make up the highest loss amounts.⁴⁰ These figures are an indication that bank-offered payment solutions are not immune to fraudulent activities. Despite its various design features, Pay-by-Bank, too, could fall victim to payment fraud.

Pay-by-Bank could introduce legal and regulatory compliance risks. Looking at some existing Pay-by-Bank deployments, fraud liability and dispute resolution processes are not always transparent and clear. For example, some deployments do not clearly outline whom a customer should engage with to initiate and resolve a dispute (that is, the bank, the third-party service provider, or the merchant), with parties shifting liability away from themselves. Such practices are confusing for customers and merchants alike and could create uncertainties around what protections apply to whom.

Any gaps in applicable customer recourse mechanisms and liability arrangements pose important consumer protection risks. In addition, they can have adverse impacts on merchants and banks, exposing them to financial, operational, and reputational risks.

Just like with other consumer payment methods, parties adopting Pay-by-Bank will need to consider time and resource commitments pertaining to customer payment queries and disputes, including those resulting from unauthorized or fraudulent transactions.⁴¹

Pay-by-Bank solutions may face significant third-party risks. As previously discussed, Pay-by-Bank relies on various third-party service providers to facilitate key payment processes. These service providers may not have the same levels of security controls and monitoring tools as banks, thus possibly making them more vulnerable to malicious activities.

While third-party payment risks are not unique to Pay-by-Bank deployments, the relative novelty of open banking technology and resulting provider arrangements requires risk mitigation and management practices to be vetted, particularly those pertaining to data privacy, cybersecurity, and operational risks more broadly.

Instant Pay-by-Bank considerations

The benefits and risks of Pay-by-Bank could be exacerbated if routed over instant payment rails. An increasing number of Pay-by-Bank deployments are expected to offer routing via instant payment rails, in addition to ACH, which could amplify both the gains and drawbacks described above.

For example, Pay-by-Bank transactions that are settled instantly, irrevocably, and 24x7x365 could provide greater certainty about funds availability to merchants, thereby enhancing their financial planning and cash flow management activities and reducing exposure to credit and liquidity risks.

As instant payment systems conduct real-time funds verification during payment authorization, the risk of chargebacks or payment failures due to insufficient funds in a sender's account is minimized. This could protect customers from overdrawing their accounts and accruing associated penalties or fees. Real-time funds availability could also support budgeting and money management efforts, as buyers would see their remaining account balance in real time, rather than upon deferred settlement, as is the case with ACH transfers.

However, instant payments are generally considered final and irrevocable, posing additional fraud prevention and detection challenges and aggravating the risk of unauthorized or fraudulent account takeovers resulting in irreversible debits.⁴²

In addition, operational disruptions or outages can have an immediate impact on the flow of funds and may result in customers and merchants being unable to complete transactions in real time. Operational failures in deferred settlement systems, on the other hand, may not always be noticeable to end users—provided that incidents get resolved before settlement.

Finally, some customers may prefer a delayed (versus instant) debiting of their accounts to allow for more time to fund transactions. The growing popularity of products such as Buy Now, Pay Later, alongside credit cards, could presumably be attributed to similar motivations.

Section 4: Next steps in research

Pay-by-Bank is a trending topic in the consumer payments landscape. For the merchant payments use case in particular, Pay-by-Bank could offer a range of benefits as well as introduce new risks to consumers, merchants and financial institutions.

For instance, in the absence of network intermediaries, merchant fees could be lower than for credit card transactions. Pay-by-Bank's reliance on fewer intermediaries could also reduce exposure to operational risks; identity verification and access control measures built into Pay-by-Bank solutions may lower the risk of unauthorized or fraudulent transactions, which, in turn, could relieve merchants from managing costly payment disputes and reversals.

As a bank-offered payment solution, Pay-by-Bank users could benefit from consumer protection requirements and other regulatory safeguards that banks must comply with. Banks could see Pay-by-Bank as an opportunity to compete with emerging nonbank payment methods and retain customer relations.

On the flip side, however, Pay-by-Bank comes with several uncertainties: The cost savings that merchants may or may not experience by adopting this payment method need further exploration. This may include scrutinizing upfront and ongoing operational expenses, as well as potential security and compliance costs. The case for or against Pay-by-Bank will further depend on factors such as a merchant's business type, average transaction volumes and values, and typical customer base.

Future research could further explore potential factors driving adoption behaviors: For customers, the potential additional security layers of Pay-by-Bank transactions may not be enticing enough to give up spending rewards, perks, or the extension of credit offered by existing payment methods, most notably credit cards. Pay-by-Bank adoption could be incentivized with merchant discounts, but such promotions would impact the cost savings calculations of merchants themselves. Similarly, Pay-by-Bank could undermine banks' lucrative card business, and introduce new operational, as well as regulatory and compliance risks. Merchants and customers, too, could face uncertainties around fraud liability arrangements and dispute resolution processes for Pay-by-Bank transactions. Finally, the various operational, liquidity and fraud risks could be exacerbated if Pay-by-Bank transactions are routed over instant rails.

As more Pay-by-Bank deployments come to market, the outlined benefits and risks could become more apparent or be contested with new insights. Some questions that should stay at the forefront of future discussions include: What consumer protection measures, including liability rules, ought to apply to shield consumers and merchants from potential misconduct and fraud? What safety and security measures should financial institutions be required to comply with to mitigate the various risks pertaining to open banking technology?

For the time being, Pay-by-Bank presents yet another addition to financial institutions' multi-rail payment offerings and merchants' and consumers' vast pool of payment options.

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