In this blog, Head of Policy, Kate Fitzgerald reflects on the implementation of our APP scams requirements and gives an update on the next steps.
On 7 October, our new requirements, seeing world-leading protections for victims of APP scams came into effect. Payment firms in the UK have been implementing the protections and making sure victims are reimbursed in line with our requirements. While there is currently reporting and claims management processes in place, we want there to be a consistent approach to this, which is why we have been keen to see a centralised system be implemented by Pay.UK for use by all directed PSPs.
In terms of what our plans look like, we plan to publish a consultation on APP scams, seeking views on whether to put in place regulatory requirements for Pay.UK’s reimbursement claims management system (RCMS) for the purpose of APP scam claim management and data reporting. We plan to publish this in April 2025 and consult for at least eight weeks.
The story so far
In April 2024, we consulted on proposals to put requirements in place for PSPs to use Pay.UK’s RCMS. In that consultation, we set out our view that Pay.UK’s RCMS would provide a secure environment for all PSPs to manage and communicate in respect of reported APP scam claims, as well as supporting Pay.UK to monitor and manage compliance with the FPS reimbursement rules.
In July 2024, after having considered the responses we received to the consultation, we published our policy statement. This confirmed that while we continue to see benefits in a system run by Pay.UK and used by all PSPs for APP scams claims management and data reporting, we were not at that time putting in place regulatory requirements for the RCMS on either Pay.UK or PSPs.
We confirmed that we would reconsult on proposals to require use of the RCMS. This was so that industry could focus on successful implementation of the policy on 7 October 2024, and to make sure we and stakeholders had all the information necessary, and sufficient time, to consider the costs, benefits and impacts of our proposals.
We continue to recognise the important role that existing industry claims management systems have played in implementation and the role of UK Finance. We also recognise that some APP claims are being managed manually and that these arrangements have operational impacts for PSPs, who continue to focus on ensuring consumers are protected in line with the policy.
Next steps
Our plans to consult on RCMS proposals in April 2025 recognise that preparing for and implementing this ambitious policy has required significant effort from across stakeholders. We also know it is important that we provide certainty and clarity on our plans, and the timing of our RCMS consultation. While we had previously signalled that we may look to put regulatory requirements in place for the RCMS in May 2025 (if confirmed following consultation) this is no longer feasible.
That means, we will be asking for your views on the potential implementation date for any requirements, as part of our April 2025 RCMS consultation. We anticipate that the earliest possible date for any requirements confirmed following consultation to come into effect is likely to be late 2025, but this remains subject to the consultation and our consideration of the responses received.
We want to ensure that stakeholders have sufficient time to consider our proposals and submit their views on them. Please get involved – your feedback is critical to ensuring the most effective outcome.
Stay in touch
Of course, we’d appreciate ongoing engagement throughout this and the team will be happy to speak to stakeholders ahead of, as well as during, the consultation process. Please email appscams@psr.org.uk if you’d like to share your views with us.