The payment field is being rapidly transformed. New players have emerged and are threatening the well-established positions of the incumbents. This process is driven by technology change and market forces, and it is shaped by the increasing role of the regulator. When considering the change in the regulatory environment and combining it with the disruptive and innovative nature of the mobile phone, the result is a market that is rapidly transforming from well-established structure into a state of flux. We build a model to understand and explain this transformation of the digital payment infrastructure. The model captures the formation and development of the digital payment infrastructure with a particular emphasis on the regulator´s and innovator’s perspective. It consists of four stages characterized by slow incremental change which are followed by short and rapid bursts of discontinuity. Each stage is portrayed by its evolutionary dynamics, the nature of the payment platform, the legal implications, the level of competition, and what drives the discontinuity. Keywords: digital payments, multi-sided platform, EU payment regulation, digital infrastructures.