The PLG Framework
Two interconnected frameworks for managing payment product compliance across the full regulatory lifecycle.
Payment Lifecycle Governance (PLG)
The PLG Framework provides a structured methodology for mapping every payment scheme obligation to one of six control categories — enabling first-line compliance teams to build, maintain, and audit their obligation landscape systematically.
The framework's core proposition is that no payment obligation falls outside these six categories. Every regulatory requirement, every scheme rulebook clause, every customer-facing duty maps to exactly one of the six controls. This creates a complete, non-overlapping, and mutually exclusive taxonomy for payment compliance.
Read the White Paper →The Six Control Categories
Customer Journey
Controls governing how payment obligations manifest at the point of customer interaction — onboarding, initiation, authorisation, and dispute resolution.
Failure Handling
Controls governing how the payment system responds when transactions fail, time out, or are rejected — including refund obligations, notification requirements, and remediation timelines.
Monitoring
Controls governing continuous observation of payment flows for regulatory compliance — transaction monitoring, scheme reporting, and audit trail obligations.
Regulatory
Controls that directly implement specific regulatory obligations — PSR, FCA requirements, SEPA regulation, and jurisdiction-specific payment law requirements.
Scheme Control
Controls derived from payment scheme rulebook obligations — EPC rules, Bacs requirements, Faster Payments participation standards, and scheme-specific compliance requirements.
Customer Feedback
Controls governing the capture, handling, and regulatory reporting of customer feedback, complaints, and dispute outcomes related to payment services.
No integration creates a seventh control.
Core axiom of the PLG Framework
The payment compliance lifecycle
01
Design
Scheme selection, regulatory scoping, obligation identification
02
Build
Control architecture, six-category mapping, gap analysis
03
Launch
Pre-launch compliance assurance, baseline capture
04
Operate
Continuous monitoring, drift detection, obligation updates
05
Review
Periodic reassessment, RDI scoring, gap remediation
Regulatory Drift & the RDI
Regulatory Drift describes the process by which a payment product that was compliant at launch progressively diverges from its regulatory baseline — not through deliberate non-compliance, but through the accumulation of scheme changes, regulatory updates, and product evolution that governance structures fail to absorb.
The Regulatory Drift Index (RDI) is a composite scoring mechanism that quantifies the degree of drift for a given payment product or scheme participation at a point in time, enabling prioritised remediation.
RDI Score Bands
RDI Contributing Factors
Key Insight
"Regulatory drift is not caused by negligence. It is caused by the absence of a governance structure capable of absorbing continuous change without manual intervention."
— PLG Framework, Publication 001