The next phase of payments may not look like a bank card, a banking app or a point-of-sale termina at all. Instead, it may look like a game controller, a watch, a ring, a car dashboard, a television remote, a wearable device or any other connected object that can initiate, authenticate or transmit payment information.
Recent reports about Sony Interactive Entertainment’s published patent application for a PlayStation controller-driven payment information transfer system are interesting far beyond just the gaming industry. The application reportedly describes a controller acting as a bridge between a nearby payment device, such as a phone, card or gift card, and a console, allowing payment information to be transmitted without the user manually entering card details into the console. It remains a patent application, not a confirmed product launch, but the concept is commercially important because it reflects a wider movement in payments: the checkout is moving into the devices that consumers already make use of.
For South Africa, the issue is not whether a PlayStation controller will become a payment device. But rather, what happens when payment functionality is embedded into ordinary digital environments, those that were never designed to primarily function as financial infrastructure.
Gaming is a useful example because it brings together many features that make embedded payments both attractive and legally complex: the customer is already authenticated, the purchase journey is digital, delivery may be instant, transaction values may be small but frequent, users may be minors or on family accounts, and the platform may be offshore. In that context, a smoother payment flow is not just a convenience feature. It changes how payment risk is allocated.
SARB and regulatory risks
South Africa’s payments framework is already moving in a direction that makes this kind of development rather notable. The South African Reserve Bank (“SARB”) has identified payments as a strategic priority under Strategy 2030, and its Payments Ecosystem Modernisation Programme aims to enable fast, simple, inclusive and secure digital payments across South Africa. SARB has also indicated that the modernised ecosystem will serve a broader range of payment service providers, including banks, fintechs and non-bank entities, and will support interoperability between participants in the domestic payment environment.
That regulatory direction matters because embedded payments often involve entities that do not look like traditional payment institutions. A gaming platform, retailer, telco, marketplace, social media platform or software provider may become part of the payment journey without becoming the issuer of the payment instrument or the merchant acquirer. The payment may still be processed by a bank, card scheme or authorised payment provider, but the customer’s experience is controlled by the platform.
This raises a familiar regulatory question in a new setting: who is performing the payment activity?
In a traditional card transaction, the roles are relatively well understood. There is a cardholder, issuer, merchant, acquirer, scheme and processor. In an embedded payment model, those roles may still exist, but they are often hidden behind the user interface. The consumer may tap a phone on a controller, confirm a purchase through a device, or rely on stored credentials linked to an account. The payment infrastructure remains regulated, but the visible point of interaction may be a non-financial device.
Activity-based regulation matters here. SARB’s National Payment System Department regulates payment systems, financial market infrastructures, settlement systems, payment clearing house system operators, system operators, third-party payment providers, e-money providers and other participants in the national payment system. The regulatory focus is increasingly on the function performed and the risk created, not only on the traditional identity of the institution performing it.
The legal issues are not limited to payment authorisation. Embedded payments also raise questions around consent, authentication, data security, chargebacks, refunds, recurring payments, vulnerable consumers, minors and the storage or transmission of payment credentials.
If the device is merely transferring tokenised credentials, the risk profile may be different from a model in which raw payment information is stored or transmitted. If the customer is using a wallet or saved card, the disclosure and consent journey becomes central. If the platform allows rapid in-game purchases or subscription upgrades, consumer protection and spending controls become part of the regulatory conversation.
This is especially important in South Africa because digital payments reform is not only about speed. It is also about trust, inclusion and resilience. The SARB’s Payments Ecosystem Modernisation work is aimed at a safer, faster and more accessible payment ecosystem, and Deputy Governor Rashad Cassim has described payments as both systemically important and one of the most active areas of innovation in South Africa and globally.
Embedded payments will only support that objective if users understand when they are paying, what payment method is being used, who receives their payment information and how they can dispute or reverse an unauthorised transaction.
What should businesses take note of?
For businesses, the practical lesson is that payment design is becoming legal design. A product team may see fewer clicks. A regulator may see a payment initiation point. A consumer may see convenience. A risk officer may see authentication, fraud and data protection questions. Each of those perspectives matters.
The device may be new, but the underlying questions are not. Who holds the customer relationship? Who initiates the payment? Who authenticates the payer? Who stores or transmits credentials? Who is responsible for failed, mistaken or unauthorised payments? Who deals with complaints? Who is accountable if the technology makes payment too easy, too opaque or too difficult to control?
As more connected devices become capable of initiating or facilitating payments, South African businesses should avoid treating payment functionality as a minor product feature. Any business embedding payment capability into a platform, device or customer journey should assess whether it is performing a regulated payment activity, relying on a regulated partner, processing personal information, creating consumer credit or subscription risk, or changing the way customers consent to transactions.
The future of payments may not be defined by a new card or app. It may be defined by the disappearance of the checkout into everyday digital experiences. The regulatory challenge is to make sure that, as payments become more invisible, accountability does not.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
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