APP scams reimbursement dashboard – how well is the UK responding to scam claims?

Posted on: 5 August 2025

Written by: Jaspreet Kaur

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 remains as a very topical area for payment, e-money firms and banks at the moment, with intrigue amongst the masses as to how industry has responded to the UK’s controversial APP fraud reimbursement proposal from the PSR since 07 October 2024; And so the PSR’s data report outlines an informative narrative on how well the payments sector is responding to APP scams - and indicates the ‘direction of travel’ for the coming months. The report provides statistics for Faster Payments system (FPS) transactions within the reporting period from 07 October 2024 to 31 March 2025 that provides two datasets from Q4 2024 and Q1 2025 for comparison. 

Generally, the data shows that firms are actively reimbursing victims of APP fraud meaning the reimbursement process operates in line with regulatory expectations and providing some relief to victims of scamming in the country; The total value of reimbursement awarded to claimants increased from £27.6 million in the previous quarter to £38.4 million in Q1 2025. This indicates a steady ascent to better victim compensation and industry’s willingness to adapt to an influential change in payments policy. Interestingly, it would be useful to see data on the costs to the payments sector in maintaining the reimbursement process, providing a vantage viewpoint of reimbursement in its entirety. 

 

It seems that consumer confidence in the reimbursement process had grown from the previous quarter in Q1 2025 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 amounting to 43,600 victims receiving reimbursement pay-outs. One reason for this may be that some firms may consider the facts of the APP scam to better align with the requirements of a civil dispute claim, excluding it from eligibility for reimbursement.

 

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). While its disappointing news for the customer, some firms’ chose to reimburse the customer through their internal dispute management policies, though this may not be submitted as reportable data on the RCMS to Pay.UK.

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 of 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 indicating customers were not being ‘cautious enough’ in meeting the standard of caution test within 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 in identifying their transaction as 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 viewed prima facie as it has been analysed by the PSR in line with its definition of APP fraud and reimbursement only (as per its consultations and Specific Direction 20). Comparatively, the data from UK Finance has a broader definition which could provide different results and perspective on reimbursement progress 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, it's 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 channel rather than an external payment systems such as CHAPS and FPS;
  • Data may have been revised after publication of the PSR’ report 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 reflect industry’s current response to managing APP fraud as effective. 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 their reimbursement claim processes are properly designed and staff are adequately trained in APP fraud management.

What should firms do now?

  • Review your reimbursement claims process – Is it working effectively? Is it a consistent and measurable process?
  • Monitor reported data – Does it make sense? Is it showing a proportionate number of claims vs fraud incidents?
  • Check staff understanding of APP scams – Do they truly understand the various scam typologies and claims process? Are they looking after scam victims?

APP Fraud management is a tricky area for firms. If you have any questions in this area, or would like to discuss how we can help to ensure that your reimbursement process  works appropriately for your business model, please get in touch for support. 

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Jaspreet Kaur

Jaspreet is a Senior Consultant within our Digital Finance team.

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