Card Program Complexity Puts Scale-or-Stall Pressure on Issuers

However, as their reach expands, so does their complexity, turning program execution into a challenge rather than a back-office task.

PYMNTS Intelligence’s December Embedded Finance Tracker report, “To Own or Outsource? Directions in Payment Program Strategy,” found that launching and growing a payment card program now requires coordination between issuing banks, payment networks, processors, compliance partners, fraud tools and customer support functions.

A card program is not simply the issuance of a debit or prepaid card. It is an end-to-end financial product that spans compliance, settlement, user experience, lifecycle management and ongoing optimization.

The report revealed that program management is the operational engine that keeps all these elements aligned, transforming complexity into a competitive advantage rather than a liability.

What Makes a Card Program Effective

Effective card programs share several defining characteristics. They are built with clear governance structures, defined roles and transparent reporting, allowing stakeholders to see performance and risk in real time. Strong programs also emphasize modular design, enabling components to be adjusted or replaced without disrupting the entire system.

Equally important is oversight across the full card lifecycle, from design and technical integration through post-launch optimization and cardholder support. Programs that succeed are those that balance speed to market with regulatory rigor, rather than treating compliance as an afterthought.

Two Ways to Build Card Programs

The report outlined two primary approaches to building card programs.

The first approach is owning program management in-house, a model typically favored by large, mature organizations with established compliance teams and operational scale. This approach offers maximum control and direct access to data but requires investment and ongoing supervision.

The second approach is outsourcing program management to an experienced partner. This model is often adopted by early-stage FinTechs, non-financial brands and companies seeking faster launch timelines without building internal infrastructure. Increasingly, organizations are blending these approaches into hybrid models that retain strategic control while delegating operational complexity.

Why Outsourcing Is Gaining Ground

Outsourcing card programs has evolved beyond a tactical decision. The report showed that outsourcing can accelerate readiness by using pre-integrated technology, established bank and network relationships, and proven compliance frameworks. This allows organizations to focus on customer experience and growth while relying on partners for executional heavy lifting.

Outsourcing does not mean relinquishing control. The strongest models extend internal capabilities, enabling firms to pivot faster as regulations, customer expectations and use cases change.

Top reasons companies outsource card programs:

• Speed to Market
  Outsourcing shortens launch timelines by using existing integrations and approved frameworks, benefiting brands eager to monetize quickly.
• Regulatory Confidence
  Partners bring embedded compliance expertise, reducing risk for companies without deep regulatory teams.
• Operational Scalability
  Outsourced models support growth without requiring proportional increases in internal staff or systems.
• Cost Predictability
  Sharing economics with partners can lower upfront investment and smooth operating expenses.
• Focus on Core Business
  Non-financial brands can use card programs to enhance loyalty and engagement while staying focused on their primary offerings.

Card programs have evolved into complex, multiparty financial products where execution matters as much as strategy. Effective program management now determines whether a card program launches on time, stays compliant and scales sustainably.

For many organizations, outsourcing all or part of program management has become the most practical way to balance speed, oversight and flexibility, allowing companies to focus on customer experience and growth while relying on proven partners to manage regulatory, operational and technical demands.

At PYMNTS Intelligence, we work with businesses to uncover insights that fuel intelligent, data-driven discussions on changing customer expectations, a more connected economy and the strategic shifts necessary to achieve outcomes. With rigorous research methodologies and unwavering commitment to objective quality, we offer trusted data to grow your business. As our partner, you’ll have access to our diverse team of PhDs, researchers, data analysts, number crunchers, subject matter veterans and editorial experts.