Jurisdiction(s):
United Kingdom

UK Authorised Push Payment (APP) Fraud Reimbursement Regime: FPS and CHAPS Rules, 50:50 Sharing, £85,000 Cap, Exceptions, Deadlines, and FCA/PSR/BoE Oversight

Published by a LexisNexis Financial Services expert

Practice notes

Introduction

On 7 October 2024, the Payment Systems Regulator (PSR) and the Bank of England unveiled a compulsory reimbursement regime for payment services providers (PSPs) when customers fall victim to Authorised Push Payment (APP) fraud. As the PSR describes it, APP fraud arises where a criminal deceives someone (often a consumer) into sending funds to an account they do not control. The principal scam types include:

‘malicious payee’—for example, a fraudster induces a person to pay for goods that do not exist or are never delivered;
‘malicious redirection’—for instance, a criminal impersonates a member of bank staff to persuade someone to move money from their bank account into the fraudster’s account.

In-scope payment firms

The APP fraud reimbursement duty applies to these categories of payment firms:

all payment firms participating in the Faster Payments Scheme (FPS) that provide relevant accounts; and
all payment firms participating in the Clearing House Automated Payment System (CHAPS) that provide relevant accounts.

These entities were expected to comply with the...

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Gavin Punia

Bird & Bird

I am a regulatory specialist with a particular focus on advising firms who are digitally transforming the way financial services are being delivered.I have developed a diverse range and in-depth experience of retail and wholesale financial services, including advising firms in the payments, brokerage, wealth management and crypto sectors. I offer particular experience in the regulation of payment services and electronic money products, crypto, investment services and insurance broking services. I provide advice to payment service providers across the payment chain, including issuers, account operators, payment initiation providers, merchant acquirers and merchants, including e-commerce platforms.The UK regulatory framework has constantly evolved over the last decade and the combination of advising clients on new financial services regulation with the development of new digital technology enables me to give practical and pragmatic advice. This ranges from organisational or governance requirements to advising on product specific issues across the...

Alice Drain

Bird & Bird

I am an associate in Bird & Bird’s Finance & Financial Regulation team, specialising in financial services regulation.I assist clients across the financial services sector with a variety of regulatory and compliance matters, including payment services and e-money, payment system issues, perimeter guidance and financial promotions.I trained at Bird & Bird. Before joining Bird & Bird, I worked in a variety of in-house roles at listed companies, with a focus on ethics and compliance. I have particular experience in financial crime issues covering anti-bribery and corruption, whistleblowing, and investigations....

Web page updated on 22/05/2026

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