Subject: PaaS

Closed-loop payment programmes

closed-loop payment programmes

A closed-loop payment programme is a payment system where funds can only be spent within a defined and controlled environment. This may include a specific merchant or group of approved merchants, a restricted range of goods or services, or a particular programme or location. Unlike general-purpose payment cards, closed-loop payments are designed for purpose-specific use rather than unrestricted spending.

Closed-loop payment programmes are widely used across events, retail, employee benefits, aid distribution and public-sector schemes. Yet the term itself is often poorly explained, leading to confusion about how these programmes work, how they differ from traditional card payments, and where they fit within the regulatory landscape.

This guide explains closed-loop payment programmes in clear, practical terms. It covers how they work, why organisations use them, and how they are defined under European payments regulation, without relying on legal jargon or marketing language.

What is a closed-loop payment programme?

A closed-loop payment programme is a payment system where funds can only be spent within a defined and controlled environment. They allow companies to embed payment functions without obtaining a full Payment Institution (PI) or Electronic-Money Institution (EMI) license.

Unlike general-purpose payment cards, which can be used almost anywhere, closed-loop payments are restricted in one or more ways. This might mean the payment instrument can only be used:

  • With a specific merchant or group of approved merchants
  • For a limited range of goods or services
  • Within a particular programme, location, or country.

Because acceptance is controlled, the organisation running the programme has much greater oversight of how funds are used. In simple terms, closed-loop payments are designed for purpose-led spending, rather than open, unrestricted use.

How closed-loop payment programmes work in practice

In a closed-loop payment programme, a single provider manages the payment ecosystem end to end. This typically includes issuing the payment instrument, defining where and how it can be used, processing transactions within a controlled network, and settling funds with participating merchants. Because transactions remain within the same system, spending rules and reporting can be applied consistently.

This structure allows organisations to introduce:

  • Merchant or category restrictions
  • Spending limits or rules
  • Faster settlement and clearer reporting
  • Greater visibility over how funds are allocated and used

In practice, this structure also gives organisations clear visibility over how funds move through the programme. Administrative platforms, such as the management portal provided by DiPocket, allow programme owners to monitor transactions, apply or adjust spending rules, and review detailed reporting across cards, users and merchants. This level of insight supports oversight, reconciliation and decision-making throughout the life of the programme.

Closed-loop vs open-loop payments: which do I need?

The choice between closed-loop and open-loop payments lies in acceptance and control.

Open-loop payments
Open-loop payments (such as standard debit or credit cards) operate across wide merchant networks. Multiple parties are involved, including issuing banks, acquiring banks and card schemes, and the card can be used at millions of merchants worldwide.

Closed-loop payments
Closed-loop payments (such as those set up for cashless events) operate within a defined network set by the programme owner. This is designed to limit where and how funds are spent, enabling tighter control alongside narrower use.

For organisations that need unrestricted consumer spending, open-loop payments make sense. For organisations that need control, traceability, or purpose-specific spend, closed-loop programmes are often a better fit.

How closed-loop payment programmes are defined under PSD2

From a regulatory perspective, closed-loop payment programmes are commonly understood within the framework of the EU’s second Payment Services Directive (PSD2).

Under PSD2, certain payment instruments are recognised as having limited acceptance or limited purpose. These include instruments that can only be used:

  • Within a defined network of merchants
  • For a restricted range of goods or services
  • Or within a single country for specific social or public-sector purposes

Because these programmes are restricted by design, they allow organisations to introduce controls that would not be possible with general-purpose payment cards. This includes limiting where funds can be spent, how they are used, and how activity is monitored.

Organisations that choose closed-loop payment systems within these specific exclusions to the PSD2 rules gain several key advantages: they can accelerate their launch times, avoid extensive capital and reporting obligations, and optimise costs through eliminating some fees.

For users (cardholders or recipients) the impact is:

  • They can spend funds only where the programme allows
  • Payments are simpler and more predictable
  • There is less ambiguity about what the funds are for
  • The payment experience is focused on a specific purpose, not open-ended choice.

In many contexts such as receipt of benefits or aid, or the participation in events, the practical limits on payments are reassuring rather than restrictive.

For organisations delivering payments, choosing a closed-loop programme means the organisation can align the payment system directly with its operational or social objectives:

  • Funds cannot “leak” into unintended uses
  • Spending rules are enforceable, not advisory
  • Reporting reflects real programme activity, not general consumer spend
  • Compliance and oversight are easier to maintain.

Flexibility over time, and PSD3

Over time, there may be pressure to adapt your closed-loop system, for example by adding merchants or adjusting spend categories. Regulatory treatment under PSD2 is driven by how the programme is structured in practice, so it is always important to check with your provider before assuming you still have a closed-loop system.

PSD3 (Payment Services Directive 3), set to take effect around 2026-2027, aims to tighten regulations on closed-loop payment systems. It mandates stricter, clearer definitions for these exemptions, higher reporting obligations, and potential oversight for high-scale operators to prevent misuse while balancing innovation with security.

For more information on PSD3 and its impact on closed-loop programmes, please see this article from the European Payments Council. DiPocket is always ready to answer your questions on this and any other issue relating to funds disbursement systems.

closed-loop payment systems

Common use cases for closed-loop payment programmes

Closed-loop payment programmes are commonly used where control and traceability matter. Typical applications include fuel cards, cashless events, retail gift cards, employee benefits, aid distribution and public-sector schemes. In each case, the defining feature is that spending is restricted by design rather than left open to unrestricted use.

Cashless events and venues

Festivals, stadiums and large venues increasingly rely on closed-loop payments to replace cash and reduce reliance on traditional point-of-sale infrastructure.

Closed-loop programmes for cashless events allow:

  • Payments to be accepted only by approved on-site vendors
  • Faster transaction times during peak periods
  • Reduced cash handling and reconciliation effort
  • Clear reporting on vendor performance and customer spend.

Because the payment instrument is valid only within the event or venue network, operators retain control over both payments and settlement.

Retail gift cards and branded ecosystems

Retail gift cards are one of the most familiar examples of closed-loop payments.

In closed-loop programmes for gift cards:

  • Funds can only be spent within a specific brand or merchant group
  • The issuer defines where and how the card can be used
  • Unspent balances remain within the ecosystem.

For retailers, this creates predictable spend behaviour and simplified settlement, while for customers it provides a straightforward, purpose-led payment experience.

Employee benefits and controlled spending

Closed-loop programmes for employee benefits work where spend must be restricted to certain categories or providers.

Examples include:

  • Food or meal allowances
  • Travel or commuting support
  • Health, wellbeing, or lifestyle benefits

By limiting where and how funds can be used, organisations can ensure benefits are delivered as intended, while still offering employees the convenience of a card-based payment method.

Aid, social support, and public-sector programmes

Public authorities, NGOs, and aid organisations often require payment mechanisms that ensure funds are used only for approved purposes.

Closed-loop programmes for funds disbursement support this by:

  • Restricting spend to approved merchants or categories
  • Operating within defined geographic boundaries
  • Providing transparent reporting for oversight and audit

These characteristics align closely with PSD2’s recognition of payment instruments used for specific social or public-sector purposes, making closed-loop programmes particularly well suited to this context.

Security and fraud considerations in closed-loop programmes

Security is often a deciding factor when organisations compare closed-loop and open-loop payments.

Because closed-loop programmes operate within a defined ecosystem, they can reduce certain risks by design:

  • Cards or accounts cannot be used outside approved environments
  • Transaction patterns are easier to monitor
  • Unauthorised merchant usage is prevented.

This does not remove the need for robust security controls, but it does allow organisations to align payment security more closely with the specific risks of their programme.

Data, reporting and visibility

One of the most practical advantages of closed-loop payment programmes is the level of insight they provide.

Because all transactions take place within the same ecosystem, organisations can access:

  • Clear reporting on where funds are spent
  • Real-time or near-real-time transaction visibility
  • Easier reconciliation and audit trails.

For public-sector bodies, NGOs and regulated organisations, this visibility is often as important as the payment function itself.

Branded cards for closed-loop payments

Whether choosing a closed or open loop payment system, organisations have access to all the benefits of branded payment cards. DiPocket’s white-label payment cards:

  • Can be designed to carry an organisation’s own branding (rather than that of the issuing provider such as Barclaycard) and the user experience
  • Can be either physical cards, or virtual cards usable through digital devices for convenience
  • Are backed by a licensed financial institution that manages compliance, technology and settlement – the secure infrastructure that makes the funds disbursement work.

White-label cards turn a purely functional process into a branded experience. Every card carries the organisation’s identity and reinforces trust each time it is used. This combination of speed, compliance and brand visibility is why white-label cards are becoming a preferred choice for modern funds disbursement, whether for closed-loop or standard payments.

Closed-loop payment programmes and DiPocket

Closed-loop payment programmes play a vital role in payments where purpose, control, and transparency matter as much as convenience. By limiting where and how funds can be used, these programmes enable organisations to deliver payments that align closely with their operational, regulatory or social objectives.

Understanding how they work helps organisations choose the right approach for their needs. Whether used for events, benefits, retail ecosystems, or aid distribution, closed-loop models offer a structured alternative to open, unrestricted payments.

 

Considering a closed-loop payment programme?

If you’re exploring whether a closed-loop or purpose-restricted payment programme is right for your organisation, speaking with an experienced payments provider can help clarify the options.

DiPocket works with organisations across the UK and EEA to design and operate regulated payment programmes aligned with specific use cases, controls and reporting requirements.

Start a conversation with us today.

 

 

closed loop payment programmes from Di Pocket

Frequently asked questions about closed-loop payment programmes

What is a closed-loop payment programme?

A closed-loop payment programme is a payment system where funds can only be spent within a defined network, for specific purposes, or within a controlled environment.

How are closed-loop payments different from debit or credit cards?

Unlike general-purpose cards, closed-loop payments are restricted by design and cannot be used everywhere.

Are closed-loop payment programmes regulated?

Yes. In Europe, they are typically understood within PSD2 as limited network or limited purpose instruments.

Are closed-loop payments secure?

They can reduce certain risks by limiting where and how payments can be made, alongside standard security controls.

Can closed-loop programmes be used internationally?

This depends on how the programme is structured. Some are limited to a single country, while others operate across multiple regions with defined controls.

 

 

Payments as a Service explained

Payments as a Service explained
Payments as a Service (PaaS) is a cloud-based model that enables banks, fintechs, e-commerce and other organisations to outsource their entire payments infrastructure to specialised third-party providers.
PaaS providers enable businesses to integrate secure and advanced payment solutions into their platforms without the need to build or maintain complex in-house systems. PaaS solutions can include card issuing, payment processing, fraud prevention and compliance, as well as value-added services like data analytics and loyalty integration.

How PaaS works

 

  1. Cloud-based infrastructure
    A third-party provider such as DiPocket hosts and manages the payment infrastructure, including servers, databases, security and compliance protocols.
  2. Organisations access payment services via the internet, integrating them into their own products or platforms through APIs.
  3. Customisable services: organisations can select the specific payment services they need, such as transaction processing, cross-border payments and card issuing.
  4. Services including card issuing, payment processing, reconciliation, settlement and reporting are all handled by the PaaS provider.
  5. Security and compliance: PaaS providers also handle complex aspects like regulatory compliance, security, disaster recovery and system maintenance.

The benefits of PaaS

Payments as a Service providers supply fast, flexible payment solutions which offer a range of benefits over more traditional payment systems. As PaaS is cloud-based and API-driven, PaaS platforms operate in real time 24/7/365 and this delivers many benefits to organisations dealing with funds disbursement.

Cost & scalability

Traditional payment systems have high upfront costs in addition to ongoing maintenance, upgrades, and compliance. Scaling up often means additional capital expenditure and business interruption.

The total cost of payment services is lower with pay-as-you-go or subscription models. Businesses only pay for the services they use, and scaling up to higher transaction volumes is straightforward and cost-effective due to the cloud-native architecture.

Flexibility and Innovation

Organisations can also offer evolving payment technologies such as digital wallets or instant payments though their Payments as a Service provider, without performance limitations caused by onsite hardware, legacy software or an inexperienced team.

Speed to Market

PaaS offers rapid deployment into new markets, and businesses can launch new payment capabilities in weeks – accelerating innovation and responsiveness to market demands.

Card issuing

DiPocket also provides a comprehensive turnkey card issuing solution – brands can offer digital banking services with customised payment cards as part of their Payments as a Service package.

As a principal member of both Mastercard and VISA, DiPocket manages the entire card issuance process, ensuring compliance with stringent regulations. The result is a seamless and secure branded payment card solution which enhances customer loyalty as well as streamlining payment systems.

Compliance & Security

PaaS providers handle all security and compliance, including real-time fraud monitoring and regulatory updates. Providers use advanced encryption, tokenization and fraud prevention technologies to ensure secure transactions.

Cloud storage and API integration enable continuous updates, allowing businesses to stay current with maintenance and security requirements without requiring in-house support. Managed in-house, these would require dedicated teams and resources: PaaS reduces this operational burden and risk for businesses.

What kind of organisations use Payments as a Service

PaaS empowers organisations of all sizes to set up a quick and efficient payment infrastructure. Businesses using PaaS include:

  • Non-financial businesses offering financial services (e.g., retail companies adding payment options).
  • Financial institutions expanding their product portfolios without building new infrastructure.
  • eCommerce startups seeking cost-effective ways to integrate advanced payment capabilities.
  • Companies refreshing their payments infrastructure to streamline disbursements such as employee benefits, expenses payments and payroll.
  • Organisations looking to streamline diverse disbursements, using a fast and effective payment disbursement system that can handle cross-border payments, making payments to recipients without a bank account or in a cashless environment, and even issuing payment cards limited to specified purposes.

organisations who use Payments as a service

Use Cases for PaaS

DiPocket’s Payments as a Service payment disbursement solution supports organisations across Europe, helping them to deliver funds quickly and safely to their destination. Our customers use PaaS for:

Funds disbursement –  issuing funds for payroll, expense management, gift incentives etc

Loan disbursement – allowing lenders to manage loan disbursement and repayment.

Employee benefits – a streamlined, cost-effective and tax-efficient way to reward staff and pay bonuses.

BIN sponsoring – sponsored Bank Identification Number (BIN). A ready-made outsourcing solution for financial institutions that want to enrich their offer with cards and virtual IBAN numbers, enabling them to work with a strong network of partner banks including Mastercard or Visa, SEPA and SWIFT members.

Gift cards – issue single or reloadable gift cards for everything from gifts to product rebates and refunds, compensation for travel delays and client incentives.

Cashless events – an easy and economical way to set up a cashless system. Using standard VPOS terminals and custom branded interfaces, customers can give users full control over spending and increase awareness of their brand.

Payment market trends

The PaaS market is experiencing rapid growth, driven by demand for digital payments, regulatory complexity and the need for agile, cost-effective solutions. The PaaS market was valued at USD 14.52 billion in 2025, according to Mordor Intelligence, and is forecast to reach USD 58.77 billion by 2030.

While traditional payment processors offer an all-in-one solution with little opportunity for customisation, Payment as a Service providers can operate differently. PaaS allows the customer to decide which features they need, and to customise their payments to meet the needs of both their business and their customers.

As payment market trends continue to change and the technology continues to evolve, cloud storage and API-based PaaS solutions enable organisations to lead the way in providing payment disbursement solutions tailored to their users’ needs.

 

Conclusion

PaaS is a modern, flexible, and cost-effective alternative to traditional payment systems. It enables faster innovation, easier compliance, greater scalability, and lower operational complexity—making it especially attractive for businesses seeking to modernise their payment infrastructure and respond quickly to changing market and regulatory demands.

If you’d like to find out more about DiPocket’s Payment as a Service solution, what it costs and how it can help your organisation, please contact us – we are here to help!

Leading-edge corporate payment solutions

corporate payment solutions
Disrupted by digital services, the global financial services landscape is rapidly being reshaped. Traditional banking is giving way to more flexible payment solutions that give organisations greater control over their funds, and deliver an enhanced customer experience.

What organisations can benefit from these changes?

Organisations from large corporations to SMEs, charities and even banks can now buy Payments as a Service (PaaS), leaving the complex financial and compliance obligations to the provider.

DiPocket provides a fully managed platform giving you control of payments, supported by our comprehensive security, technical and financial checks. DiPocket’s funds disbursement solution includes the provision of customisable payment cards, and is supported by Visa, Mastercard, Google Wallet and Apple Pay.

Is DiPocket a bank?

No, DiPocket Group is a European PaaS provider, complementary to and independent from banks. We are licensed to operate in Europe (through Lietuvos Bankas in Lithuania) and are regulated in the UK by the Financial Conduct Authority (FCA). DiPocket is a principal member of both Mastercard and VISA, is a SEPA participant and SWIFT member.

We invest heavily in the licencing and operational capabilities typically handled by banks to provide our customers with simple, safe and effective card issuing and funds disbursement solutions.

How does Payments as a Service work?

Whenever you need to move money, this is achieved quickly and effectively through your PaaS system. At DiPocket, we take care of the whole payment and technology infrastructure, so that your customers make or receive payments through a simple and frictionless system. Payments can be made in near-real time, to different countries, and can be added to a customised payment card even if the recipient has no bank account.

Why might you want a bespoke payment solution?

Disbursing funds can be complex and time consuming. By using a PaaS provider, you can quickly make tailored payments for purposes including:

  • Disbursement of funds – including payroll, grants, and financial support
  • Disbursement and repayment of loans
  • BIN sponsorship
  • Employee benefits
  • Gift cards
  • Cashless events

What applications are there for PaaS?

Customers use bespoke payment solutions for a wide range of purposes, including:

Funds disbursement

A simple and cost-effective way to issue funds for payroll, expense management, gift incentives and more. We supply virtual or physical cards with your own branding, which can be set up to your requirements: for example, limited to specific services, shops or classes of goods.

Loan disbursement

A personalised card issuing and virtual payment solution for lenders to streamline disbursements. You manage loan disbursement and repayment, with full control and usage restrictions to prevent over-spending and defaults.

Employee benefits

Enrich your employee offering through branded physical or virtual cards for gym entry, restaurants, shopping and more. DiPocket offers a streamlined and cost-effective mechanism to reward staff and pay bonuses in a tax-efficient manner.

Customised debit cards

Offer your own branded payment card with Visa, Mastercard, Google Wallet and Apple Pay payment options, fully set up and supported by your BaaS provider.

Our payment card solution gives you complete customisation of your funds disbursement to suit your requirements. You can:

  • Specify the currency and country of use
  • Limit payments to particular shops, services or category codes
  • Give real-time access to funds
  • Raise brand awareness and engagement
  • All this is delivered quickly and cost-effectively through our turnkey card issuing & funds disbursement solution.

Simplified financial management

‘Banking as a Service’ solutions help you by removing the burden of day-to-day management of funds disbursements. You benefit from:

  • A powerful portal which streamlines all disbursements
  • Detailed reporting
  • Complete visibility in real time
  • The ability to automatically top up cards
  • A fully managed solution without integration
  • APIs for integration with your existing platform

Leading-edge corporate payment solutions from DiPocket

Our team of over 100 people is trusted by organisations across Europe and the UK to deliver state-of-the-art withdrawal and payment solutions that make your life easier.

If you would like to find out more about our white-label funds disbursement solutions, please get in touch.

Contact us today