Revolut tests facial-recognition payments in London cafés

Revolut tested a checkout system that let customers pay by having their face scanned instead of tapping a card or phone. The pilot, called Pay with Smile, ran for three days, from 24 to 26 September 2026, at three Kiss the Hippo cafés in London: Bloomsbury, Chelsea and Soho. It has already ended.

Only Revolut customers who had opted in could use the feature, and only at those three tills. Anyone else paid as normal, by card or phone wallet. The trial matters to UK merchants and Revolut customers not because a nationwide rollout is confirmed. The sources reviewed for this article do not establish one. It matters because it shows how Revolut intends to handle a category of personal data that UK data protection law treats with particular care: the shape of a customer's face.

Revolut announced the pilot on 24 September 2026 through Revolut Register, its point-of-sale system, describing it as the UK's first pilot of in-store facial-recognition payments. That "UK first" description comes from Revolut's own announcement and has not been independently verified.

How the trial worked at the till

Customers signed up for Pay with Smile in one of two ways: through the Revolut app before visiting a café, or by starting enrolment at a Revolut Register terminal, which then handed the process back to the customer's phone through a tap or QR code. Either route required the customer to tick a box consenting to biometric-data processing and actively enable the feature; it was not switched on by default.

Revolut said the system worked by comparing the face captured at the till against the selfie identity checks the customer completed when they first opened their Revolut account. That is a meaningful technical point: the register does not simply reuse an old photograph. At checkout, the terminal captures a new photograph of the customer's face and converts it into an encrypted, single-use facial embedding, a mathematical representation of facial features, purely to perform that one identity match. Customers could also set an optional four-digit passcode, which Revolut says must differ from their app passcode.

If the face match failed or was inconclusive, Revolut said this did not prevent the customer completing the purchase: they could pay instead with a physical card, their phone or in-app Revolut Pay. Declining or disabling Pay with Smile at any point does not affect the underlying Revolut account.

Three cafés, three days, nothing wider yet

The scale of the trial is easy to overstate. It covered three café locations for three days. During that window, Revolut ran two promotions tied to biometric payment: speciality coffees at £1 and triple RevPoints, its loyalty currency, on transactions completed with a face scan. Customers who paid another way did not receive those terms, which matters because UK data protection guidance treats freely given consent as conditional on there being no detriment to refusing. Whether the promotion crossed that line was not addressed in the material reviewed for this article.

No figures on how many customers enrolled, attempted a face payment or completed one during the three days were published in the material reviewed.

What merchants were offered

Revolut framed the pilot partly as a pitch to independent cafés, pubs and bars struggling with the cost of taking payments. It advertised a 0% processing fee for all Pay with Smile transactions taken through Revolut Register, and cut the price of a merchant's first Revolut Register terminal.

Revolut also cited research it sponsored, suggesting independent venues face average monthly payment and infrastructure costs of £875, rising to more than £950 at pubs and bars, with lost revenue from terminal outages put at roughly £2,495 a year per venue. The sample size, fieldwork dates and methodology were not disclosed in the material reviewed, so the figures should be read as the company's own framing of the problem rather than independently verified market data.

The contractual detail behind the 0% fee, including how long it lasts, what it excludes and whether other charges still apply, was not established from the sources available. A merchant considering Revolut Register would need to check current commercial terms directly with Revolut.

Where the face data goes

This is the part of the story that outlasts the three-day trial. Revolut's Pay with Smile privacy notice, last updated 15 June 2026, sets out what happens to the checkout photograph and the embedding derived from it.

The single-use facial embedding created at each till is deleted immediately once the identity check is complete, Revolut said. But that is not the end of the data trail: a secure copy of the original checkout photograph is also uploaded to Revolut's cloud systems, where Revolut says it is kept for fraud prevention and payment-dispute purposes. Revolut does not state a fixed retention period for that image. Instead, it says the photograph and related records are kept "under its applicable data-retention policies," wording that does not tell a customer how long their face will sit on a server.

Revolut's separate announcement of the trial said merchants never store customers' personal data. That is not inconsistent with the privacy notice, but the two statements describe different things: the café's own systems may hold nothing, while Revolut's own infrastructure, and its cloud storage provider, still do. A customer reading only the "merchants don't store your data" line could reasonably conclude their face isn't retained anywhere, which the privacy notice does not support.

Revolut identifies Revolut Bank UK as the data controller responsible for this personal data in the UK, and says third-party sharing is limited to its cloud provider for storage and infrastructure. That provider's identity and where it holds data were not named in the material reviewed.

Customers have two ways to stop using the feature, with different consequences. Freezing Pay with Smile switches off face payments but leaves existing data in storage. Withdrawing consent goes further: Revolut says this immediately deletes the customer's biometric template and permanently deactivates the feature until re-enrolment. Even withdrawal, on the evidence available, deletes the biometric template rather than necessarily the checkout photographs already logged for fraud or dispute purposes.

UK privacy rules that applied

A face captured and processed to identify a specific person is special-category biometric data under the UK GDPR, according to the Information Commissioner's Office (ICO), the UK's data protection regulator. That classification carries extra legal weight: an organisation must identify both an ordinary lawful basis for processing personal data under Article 6, and a separate condition under Article 9 that specifically covers special-category data. The ICO says explicit consent is likely to be the most appropriate Article 9 condition in many biometric cases, which matches Revolut's own description of asking for consent at enrolment and again at the terminal.

For that consent to be valid, the ICO's guidance sets a specific bar: it must be specific, informed and freely given; a customer must be able to refuse or withdraw without being disadvantaged; and a suitable non-biometric alternative must be offered. Revolut did offer non-biometric alternatives, including a card, phone wallet and in-app Revolut Pay. Whether those alternatives were visible and practical enough, and whether tying £1 coffees and triple loyalty points to the biometric option during the trial sits comfortably with "freely given" consent, is not something the material reviewed settles either way.

The ICO also says organisations deploying biometric recognition must build in data protection by design and assess whether a data protection impact assessment (DPIA) is required. Current ICO guidance frames biometric-recognition systems as highly likely to trigger that requirement, rather than stating a blanket rule that every deployment must have one. Whether Revolut carried out a DPIA for Pay with Smile, and whether any regulator reviewed the pilot beforehand, was not established from the sources available.

One further caveat: the ICO's biometric-data guidance was under review as of 28 September 2026 following the Data (Use and Access) Act, so parts of the current published wording may not reflect the regulator's final post-Act position.

What is still not known

Several questions remain open on the evidence available. It is not established whether the till matched a customer's face against one preselected account or searched across all enrolled customers, a meaningful difference for both accuracy and privacy. No accuracy, bias or presentation-attack (spoofing) testing results were published. The regulatory and redress position for a disputed Pay with Smile transaction, including whether Financial Ombudsman Service routes apply, was not addressed in the material reviewed. Revolut describes itself as a UK licensed bank, but that does not automatically tell a customer what protection, if any, covers this particular checkout feature.

None of this means the pilot broke a rule, but the public record so far answers less than a customer standing at a Kiss the Hippo till might assume.

What to watch next

Readers wanting the primary detail on how their data is used should read Revolut's Pay with Smile privacy notice directly, rather than the promotional announcement. The privacy notice supplies retention and storage detail that the promotional announcement omits. Anyone weighing up whether to opt into a future version of the service should also check the ICO's published biometric-data guidance, bearing in mind that the regulator was still updating it as of late September 2026. Whether Revolut extends Pay with Smile beyond the three trial cafés, publishes usage or accuracy figures, or sets a fixed retention period for checkout photographs has not yet been confirmed.