Models of legal regulation of payment systems: a comparative analysis

The article examines the legal approaches to the regulation of payment systems in five key jurisdictions: the European Union, the United States of America, Singapore, Canada, and Ukraine. The analysis focuses on institutional mechanisms, licensing regimes, supervisory approaches, and regulatory responses to financial innovation. Based on comparative analysis, a typology of payment system regulatory models is proposed, which includes: the harmonized model (European Union), the fragmented pluralistic model (United States of America), the risk-oriented adaptive model (Singapore), the transitional model (Ukraine), and the integrative model (Canada). Each of these models is analyzed according to parameters such as the level of regulatory centralization, the degree of normative detail, mechanisms for consumer protection, and flexibility in the implementation of financial technologies. The study demonstrates that the European Union prioritizes comprehensive regulation and consumer protection (in particular, within the framework of Directive (EU) 2015/2366 of the European Parliament and of the Council of 25 November 2015 on payment services in the internal market (PSD2) and open banking), whereas the United States of America maintains a decentralized, market-oriented approach combining federal oversight with regulatory supervision by the authorities of individual states. Singapore is characterized by a modular licensing system and active cooperation with fintech companies, including through the establishment of regulatory sandboxes. Canada’s reforms are aimed at unifying standards for both traditional and non-bank service providers. Ukraine, in turn, is adapting European approaches while developing its own model for the digital transformation of the payment sector. The research argues that effective regulation of payment systems must strike a balance between market stability and openness to innovation. Legal regulation should be proportionate, interoperable, and responsive to technological change. The findings may serve as a conceptual basis for improving Ukraine’s legal framework, taking into account global trends and further legislative reforms in the field of payment services.