On the 16 July 2025, the Payment Systems Regulator (PSR) published its dashboard on the management of reimbursement claims since its policy was imposed on in-scope firms 6 months ago. It relates to APP scam claims from payments made in the UK over Faster Payments (FPS) within the reporting period from 07 October 2024 to 31 March 2025. The data provides a comparison of industry response to consumer reimbursement claims in Q4 2024 and Q1 2025.
Generally, the data shows that firms are actively reimbursing victims of APP fraud meaning the reimbursement process is operating in line with regulatory expectations; The total value of reimbursement awarded to claimants increased from £27.6 million in the previous quarter to £38.4 million in Q1 2025.
It seems that consumer confidence in the reimbursement process had grown from the previous quarter in Q1 2025 by up to 26% as 62,600 reimbursement claims were reported by firms on the Reimbursement Claims Management System (RCMS) via reporting standard A. However, from these claims, only 30% of these claims were reimbursable that amounted to 43,600 victims receiving reimbursement pay-outs. One reason for this may be due to the app scam meeting the requirements of a civil dispute claim, excluding it from the reimbursement policy.
The data shows that more reimbursement claims were submitted to firms in Q1 2025 and 43.6% of those were actually reimbursable, with the others being rejected as the claim had fallen outside the scope of reimbursement (as per the PSR’ definition).
When investigating claims, most firms were reported to have adhered to the ‘5 business day’ requirement to close or respond to claims with 88% in Q1 2025, producing a slight increase by 6% from the previous quarter. The remaining 12% who had not responded to claimants within the timelines had not met the eligibility requirements for claiming reimbursement.
In terms of scam awareness, there was a slight increase of 1% in Q1 2025 of customers in not being ‘cautious enough’ by not meeting the standard of caution test in the investigation, resulting in a further 500 rejected complaints from the 1,100 reported in Q4 2024. In terms of total rejected claims, 3% of those were dismissed due to the consumer not reasonably demonstrating vigilance with their transaction as being fraudulent, or they hadn’t co-operated appropriately with the sending/receiving firm in the claims process.
While the data provides useful indications of APP fraud management to policy standards by industry, it mustn’t necessarily be reviewed prima facie as the data has been reviewed in line with PSR’ definition of APP fraud and reimbursement only (within consultation and Specific Direction 20). Comparatively, the data from UK Finance has a more broader definition which could provide different results e.g. claims involving international payments or non-FPS payments may be included in UK Finance calculations but not in PSR’ metrics.
In addition to this, its important to be wary of:
- ‘On us’ APP scam reimbursement where both the sending and receiving accounts are within the same firm, and the transactions pass via an internal book transfer
- Data may have been revised after report publication to reflect accurate figures of ‘late data’ received from sending firms
- The comparison does not consider the seasonal variation of APP scams e.g. the data over the summer period may show significantly higher trends where consumers travel and transact more
Overall, the results are not alarming or indicating any cause for concern, other than a natural response to mandatory policy requirements. The gradual trajectory to increased reimbursement claims and reimbursement pay-outs reflects industry’s current response to managing APP fraud effectively. A true reflection of how well firms are progressing with scams management will be apparent in the next two quarterly results. That said, firms must not be complacent and ensure that their reimbursement claims processes are properly designed and staff are adequately trained in APP fraud management.
If you’d like to discuss how we can help ensure that your firm is managing reimbursement claims effectively, please get in touch with our expert digital finance team for support.
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