Fewer Rules, Better Interoperability: Pay.UK's Case for Digital Rulebooks
By Ali Paterson · 22 September 2026

Quick Summary
David Crawford, Chief Strategy and Transformation Officer at Pay.UK, says interoperability across borders, schemes and forms of money will be a key theme at Sibos, and explains how Pay.UK is preparing: by simplifying its rulebooks and working towards a digitised rulebook that participants can interrogate.
Why does interoperability matter so much right now?
Given the global nature of Sibos, Crawford expects interoperability to be one of the defining words of the event. He sees three barriers that value increasingly needs to cross seamlessly:
- Cross-border
- Cross-scheme
- Cross-forms of money
Regardless of AI, he says, the transfer of value across those three barriers is something everyone will need to consider very carefully.
What is the problem with today's scheme rules?
No one can yet say what standard schemes or standard rules should look like. What Crawford can say is that just about every scheme in the world has evolved over time and ended up with paper rulebooks. It is not obvious at first, but when you sift through them you can extract thousands of obligations and rules that are meant to help participants understand what they should be doing.
How is Pay.UK tackling it?
Pay.UK has spent a lot of intellectual capital on this. It has looked at its own rulebooks, extracted the set of rules, deduplicated and simplified them, and wants to take that to its nth degree. Crawford does not yet know what good looks like: half the rules, perhaps a tenth. But the fewer rules there are, the easier it becomes to set the conditions for seamless transfer of value between countries, schemes and forms of money.
The next step is to move away from documents altogether. Pay.UK wants a digitised rulebook where a participant can ask which rules matter most for onboarding or for cross-border, and, using small language models, check whether a proposed course of action would meet them. It is an area Pay.UK wants to discuss and share at Sibos.
FF NEWS TAKE:
Interoperability usually gets discussed as a messaging or standards problem. Crawford's point is that the rulebook is the hidden constraint: you cannot connect systems cleanly if nobody can say precisely what each one requires. A machine-readable, radically shorter rulebook is unglamorous work, but it could do more for cross-scheme payments than another pilot.