Insight
The closed-loop market in 2026
Closed-loop payments stopped being a retail curiosity somewhere around the point that employers, fleets and campuses realised they were already running one badly, on paper.
Updated
At a glance
- Demand from
- Employers, fleets, campuses, chains
- Main driver
- Restricted spending, not loyalty
- Regulatory frame
- PSD2 limited-network exemption
- On the horizon
- PSD3, expected to tighten and grandfather
Who is actually asking
The stereotype of closed-loop is a coffee chain with an app, and that is now the smallest part of the demand we see. The larger part is organisations that need to fund a specific kind of spending for a specific group of people: meals for employees, fuel for drivers, budgets for site managers, allowances for students.
What those cases have in common is that the restriction is the point. A general-purpose card would be simpler to issue and completely useless, because the money is only being given on the condition that it is spent on particular things, in particular places.
That is why the demand has moved faster than the loyalty market around it: these organisations were already running the programme on paper vouchers and expense claims, and the closed-loop version is not a new idea to them — it is the same idea without the paper.
- Restricted spending is the driver; loyalty is a side effect where it appears at all.
- Requests reach us from fuel networks, car wash chains, corporate meal programmes, property developers, event organisers and hotel groups.
- The geography is wider than the loyalty market: EU, Ukraine, Africa, the US and Canada.
What changed to make this work
- 01
Wallets reached saturation
Apple Wallet and Google Wallet are on effectively every phone, which removed the app-install problem that killed earlier attempts.
- 02
Terminals learned to draw QR codes
The installed base can now run a closed-loop flow with no new hardware, which removed the capital cost.
- 03
PSPs became a distribution channel
Embedding a payment method in a gateway reaches thousands of merchants at once, which removed the sales cost.
- 04
The exemption stayed workable
PSD2's limited network exemption continues to cover the ordinary cases, which removed the licensing cost.
What to watch
- PSD3
- Expected to tighten closed-loop rules while grandfathering compliant programmes
- Network breadth
- A network wide enough to stop being limited loses the exemption
- Interchange pressure
- Regulated caps make closed-loop economics comparatively less dramatic
- Wallet policy
- Platform rules for passes and balances change without much notice
- B2B2E growth
- The fastest-growing segment we see, by some distance
- Consolidation
- Pass-only vendors adding ledgers, ledger vendors adding wallets
Questions about this
What is a closed-loop payment platform?
It lets you issue and process payments inside your own ecosystem — gift cards, prepaid balances, employee accounts — without routing every transaction through Visa, Mastercard or a bank. The funds stay in your system, so the fees, the data and the customer experience are yours to set.
Do my customers need to install an app?
No. Cards issue straight to Apple Wallet or Google Wallet, which are already on every phone. The customer scans a QR code with the camera, taps “Add to Wallet”, and the card is there in about ten seconds. No download, no account, no registration form.
Does it work with my existing POS terminal?
Yes. The cashier enters the amount on the terminal you already run, the terminal shows a QR code, and the customer scans it with their own phone. That works on any terminal that can draw a QR on screen, which covers modern PAX, Verifone and Ingenico fleets. If there is no terminal at all, staff can run the same flow from a phone.
Do you handle online payments too, or just POS?
Both, on one balance. There is a checkout widget for merchant sites and a direct embedding into PSP gateways as a payment method. One admin panel, one transaction ledger, one reporting stream — offline and online together.
Talk to us about where your programme sits
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