Card settlements are not a high-street index

Reportedly, £40 million is the Treasury’s estimated Exchequer gain from its wider interest-income and card-sales data measure in 2028-29, according to an HMRC policy paper published on 3 November 2026. That forecast reportedly rises to £490 million in 2029-30, while HMRC reportedly puts its own implementation cost at £68.3 million. The new merchant-acquirer return is therefore designed first as a compliance instrument: a way to match businesses, payments and tax records. It may later become useful economic evidence. Those are not the same job.

The Data-gathering (Ongoing Data: Interest and Payment Card Transactions) Regulations 2026 require relevant merchant acquirers to send monthly data to HMRC within 21 days of each month end from April 2028. The return covers every retailer with a United Kingdom address to whom the acquirer was contractually obliged to make a settlement payment during that month. Reportedly, the Government’s consultation response says there will be no de-minimis reporting threshold. A microbusiness selling a few card-paid items is in the same reporting net as a national chain, if its provider falls within scope.

That makes the feed broad for enforcement, but not comprehensive for measuring the high street. The statutory definition concerns payment cards: credit, charge and debit cards, including card-linked account numbers. It is not a census of business receipts. Cash is outside it. So are retail payments made by bank transfer or through other non-card routes. Reportedly, HMRC’s consultation response acknowledges growing use of direct account-to-account transfers and says phase one will not cover the full range of alternative payment methods. A card-settlement total is therefore a changing slice of commerce, not total sales.

Nor is the number automatically turnover, profit or taxable income. The payment chain runs from a customer’s card transaction, through an acquirer or payment facilitator, to a settlement paid to the retailer. Between those points sit refunds, fees, delayed chargebacks, VAT, split payments and agency arrangements. Reportedly, the consultation record notes that gift-card purchases create liabilities rather than sales until redemption, which the acquirer may not observe. It also reportedly records concern that chargebacks can be initiated up to 120 days after a transaction, and that client-money arrangements can make an intermediary appear to have sales belonging to somebody else. Reportedly, the Government accepts that these cases can overstate sales and says it will not fully pre-populate a tax-return box from the data.

Timing adds another layer. The reporting month is linked to the acquirer’s obligation to settle, not necessarily the date on which a customer received goods or services. The file is then due up to 21 days after month end. That is fast by tax-administration standards, but it is not real time. A later chargeback can alter the economic meaning of an earlier payment long after the first file was sent. Reportedly, suppliers asked how corrective filings would work; the published policy material does not set out a public revisions calendar for an economic series. For trend reading, a three-month trend would be less fragile than a monthly headline, but even that needs a stable definition and revision history.

The figures would also be nominal. A rise in pounds settled could mean more items sold, higher prices, consumers switching from cash to cards, a new acquirer joining the reporting population, or a combination. It cannot be called growth in real retail activity unless it is deflated, and it cannot be compared month to month without a treatment of seasonality, refunds and changes in coverage. An enforcement database can be exceptionally good at finding a mismatch between a business’s declared income and its card receipts. It can still be a poor retail index if used without those adjustments.

HMRC benefits from more frequent and standardised matching data, and the Treasury benefits from an enforcement tool reportedly expected to raise material sums. Reportedly, the policy paper says about 13 existing card-sales suppliers already report under the older notice-based regime, while standing obligations will bring smaller suppliers into scope. Acquirers pay for systems, data checks and reporting processes; retailers supply identifying information through onboarding and may have little sight of what is submitted in their name. Reportedly, the same paper says a data-protection impact assessment is still being undertaken. That is not a trivial loose end when identifiers and transaction-derived records are being combined.

The useful next step is publication, not a press-release percentage. Treasury and HMRC should publish anonymised, disclosure-controlled aggregates only after setting out what they measure: gross card payments or net settlements; treatment of fees, refunds, chargebacks and gift cards; retailer and acquirer switches; geographic and sector classifications; the share of transactions excluded because they were cash or transfers; and the date basis used for each observation. They should publish vintage files and a clear revisions-and-corrections policy, alongside a methodology explaining whether any series is seasonally adjusted or presented in real terms. Reportedly, the Office for Statistics Regulation’s standards for administrative data make the point plainly: users need to know the source’s biases, coverage and limits before deciding whether it is fit for purpose.

Publication would not turn HMRC into a retail-statistics producer by accident, nor should it disclose a shop’s confidential payments. It would let Parliament, retailers and analysts test whether a potentially valuable public dataset tells a stable story once the compliance machinery has done its work. Until then, the monthly total is a useful flag for tax administration, not a clean reading of the high street.