Author: Trevor Day Briony Krikorian-Slade

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1 ================================================================ Transport for London: paying by credit/debit in taxis Response from The UK Cards Association 24 July 2015 ================================================================ Author: Trevor Day Briony Krikorian-Slade

2 The UK Cards Association (UK Cards) is the trade body for the card payments industry in the UK, representing financial institutions which act as card issuers and acquirers. Members of the Association account for the vast majority of debit and credit cards in the UK, issuing in excess of 56 million credit cards and 95 million debit cards - and cover the whole of the payment card acquiring market. The Association promotes co-operation between industry participants in order to progress noncompetitive matters of mutual interest; develops industry best practice; safeguards the integrity of the card payments industry by tackling card fraud; develops industry standards; and co-ordinates industry-wide initiatives aiming to deliver innovation. The Association is committed to delivering improved outcomes for the customer and seeks to inform and engage with stakeholders to advance the industry for the ultimate benefit of its members consumer and retail customers. Summary There is clear customer benefit to introducing card payment acceptance in all London taxis. Credit and debit card use is increasing in all retail environments across the UK, with a 12% increase in card payment transactions and 8% increase in value in This is consistent with the customer research cited in the consultation that 83% of customers would like to be able to pay by card, for ease, convenience and safety reasons. There are also some benefits of card payment acceptance over the current app-based acceptance for taxi drivers. While app-based acceptance may have lower capital cost, card payment acceptance can provide drivers protection from liability in the case of fraud, and chargeback claims. The introduction of card payments, including contactless payments, fits with the wider TfL strategy of allowing card payments at ticket machines, and more recently the rollout of contactless payments across tube, DLR, overground and bus. This would allow a consistent customer experience across London, and would be of particular benefit to visitors, who may not be carrying cash. There are card payment devices that are particularly suited to the cab environment, such as the shuttle device, which is connected for transaction purposes through the driver s mobile phone. This particular device does not need to be fixed to the cab, but can sit in a cradle, protecting it from damage and allowing easy removal from the cab. The shuttle device can also be linked to a screen which can show advertising (bringing in a potential additional revenue stream) and can also display the final journey fare. The Payment Services Directive 2 will ban surcharging on regulated debit and credit cards from 2017; while the Interchange Fee Regulation will cap some of the fees paid by taxi drivers on regulated cards. These regulations should be factored into any discussions on surcharging and general fares. 1 UK Card Payments Summary mmary.pdf 1

3 Response to questions 1. Should passengers be able to pay by debit or credit card in all taxis in London? Yes, customers should be able to pay by debit and credit card in all taxis in London. The customer satisfaction survey cited in the consultation paper demonstrates that 83% of customers would like to be able to pay by debit or credit card, for the following reasons: ease of payment (29%), convenience (18%), not having enough cash/ saving them carrying cash or finding a cash machine (39%), and safety (7%). Generally customers expect to be able to pay with either debit or credit if card facilities are available. This would fit with the TfL policy across their network, where customers are able to buy tickets with credit or debit cards. Although there are currently a number of app-based solutions available in the taxi trade that are capable of taking card payments, these are not considered as secure as an accredited card payment terminal and usually they change a face-to-face transaction opportunity into an e-commerce transaction, which attracts a higher risk and fee ratio. The UK Cards Association provides an approval service for PIN Entry Devices (PEDs) in the UK. PEDs are evaluated against a Protection Profile, in accordance with common criteria procedures outlined by an international standard (ISO :1999). We keep a list of approved vendors and PIN entry products available on our website. 2. If passengers should be able to pay by debit or credit card in all taxis in London when should this requirement be introduced? Given the consumer benefits of paying by card, we would urge the earliest possible implementation, while allowing for the practical issues identified in the consultation. Once the consultation has run its course, time will need to be allocated for the subsequent installation of hardware equipment options, software updates and any necessary vendor product security assessments. 3. Should all taxis in London accept contactless card payments? Yes. Contactless payments are growing in popularity for low to medium value amounts (see Annex A), and customers increasingly expect to be able to use their card contactlessly where card facilities are available. This would also allow for a consistent customer experience with the rollout of EMV contactless payments on TfL s bus, tube and rail estate, which now makes up almost 20% of PAYG journeys. The contactless limit is currently 20 and under, which would accommodate the average payment of a taxi journey of 19.58, as cited in the consultation paper. Moreover, the contactless limit is increasing from 20 to 30 from September 2015, which will bring more London taxi journeys into scope. 2

4 4. Should the current maximum surcharge of 1 or 10% when paying by card be changed? As noted in the consultation, the Consumer Rights (Payment Surcharges) Regulation sets out that surcharging on card payments must be based on legitimate cost recovery. A reasonable level should become more evident as the recommended solution emerges from the consultation process. However, the Payment Services Directive 2 3 (PSD2) when it is transposed in October 2017, will also prohibit surcharging on regulated cards. Therefore, if it is determined that there is an ongoing cost recovery issue, this may need to be considered in a wider context when fares are reviewed in the next two years. Card acceptance will open up new opportunities and deliver new revenue streams that should offset some of the higher operational costs. For example, some of the technical solutions (such as the shuttle device) can be accompanied by a colour screen which may be used for running advertisements (this is used in New York, USA cabs), bringing in the opportunity for a separate revenue stream. There will also be some immediate cost benefits in speeding up payment time (especially with contactless card payments), and reducing the need for a cash float with the associated costs and risks of maintaining this. 5. If passengers should be able to pay by debit or credit card in all taxis in London, where possible, should additional costs that drivers incur be taken into consideration when reviewing taxi fares? See comments above. 6. Should the card payment devices in taxis be fixed in one position? We would advise against fixing the terminal. As well as the disadvantages set out in the consultation paper for fixing the terminal in the passenger compartment or the driver compartment respectively, fixing a terminal anywhere in the vehicle is likely to cause potential issues with vibration and affect the durability of the device. Instead, the device could be not fixed but housed in a cradle (similar to those used for satellite navigation devices). This would also allow the removal of the device when the driver is not in the cab. As in any retail environment, it is good practice for the retailer to hand the payment device to the customer to insert their card and enter the PIN. With contactless payments there is even less reason for the card to leave the customer s hand, as they simply need to touch it against the payment device. Some technical solutions, such as the shuttle device, do not require a permanent fixing and could sit in a cradle. However, if the cab owner also opted for a linked display screen for adverts and transaction flow information, this would require consideration of a) where the screen might be sited and b) any potential fixing

5 7. Should the card payment device be linked directly to the taximeter in each taxi? There are no clear benefits to linking the payment device to the taximeter. Our understanding is that the taximeter has certain regulatory requirements, and these should not be compounded by linking it to a payment solution. Similarly, linking the payment device to the taximeter may cause significant problems with assessment and approval of the chosen payment device, such as PCI-DSS implications, potentially bringing the taximeter into scope of review (as it will be handling transaction data, such as the amount). The payment process should be straightforward without linking the two devices. Once the journey is complete the taximeter will provide the transaction value amount, together with any surcharge applicable. This value can then be entered into the payment device, if the customer chooses to pay by card. This is similar to the retail environment, where typically small businesses will have bank owned terminals, so that they have to input the amount into the device if the customer chooses to pay by card. 8. If it was decided that passengers should be able to pay by credit or debit card in all taxis in London do you feel that the current signage requirements are still appropriate? It is likely that the signage requirements will need to be reviewed, to take into account the Interchange Fee Regulation. This sits alongside the Payment Services Directive 2, and caps interchange (part of the fee paid by retailers to accept card payments) for certain regulated products, but not unregulated products (which includes certain commercial cards and three-party schemes). This may result in taxi drivers accepting all cards, but surcharging on unregulated cards; or only accepting regulated cards. Both the cards which are being accepted, and the level of surcharging should be made clear to customers. We suggest that some standard wording and best practice be developed to help drivers with this. 9. Should all taxis be required to display signage showing that card payments are accepted? Yes. See comments above. 10. If it was decided that passengers should be able to pay by credit or debit card in all taxis in London should other cards, in addition to MasterCard and Visa, be accepted? Yes, the widest range of cards should be accepted, aligned with the general TfL acceptance on ticketing machines etc. The card payment solution should support any chip & PIN card and may also have magnetic stripe functionality. 11. Would you consider using a taxi (black cab) instead of using a bus, the Tube or a minicab if all taxis accepted credit or debit cards? We think the customer proposition for cabs is greatly enhanced by including card payments see comments for question 1. 4

6 Other comments TfL should also consider mandating card payments in the regulated fleet of Private Hire Vehicles. This would extend the good, consistent and secure customer experience to all taxi travel in London, and would provide a level playing field between the two branches in terms of operational costs. TfL should consider whether or not to require a receipt as part of the card payment transaction, or whether this should be optional and on request by the customer. All accredited card payment terminals should be capable of producing receipts. Contactless card payments in the UK ANNEX A There are currently 14 issuers of contactless cards, and 65m cards in circulation (63%) There are currently 238k terminals accepting contactless cards (38%) There were 380m transactions in 2014 (more than 2.5x the total of the previous 6 years) There was a 331% increase in contactless spending in

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