On 12 July 2024, the Payment Systems Regulator (PSR) issued Policy Statement 24/3: The Faster Payments APP scams reimbursement requirement: compliance and monitoring (PS24/3).

In 2023 the PSR published PS23/3 Fighting authorised push payment fraud: a new reimbursement requirement and PS23/4 Fighting authorised push payment scams: final decision.  These Policy Statements set the detailed parameters for the Faster Payments Scheme (FPS) authorised push payment (APP) scams reimbursement requirement. The PSR also published three legal instruments that give effect to the policy:

  • Specific Requirement 1 (SR1) imposed on Pay.UK. This requires Pay.UK to create the FPS reimbursement rules.
  • Specific Direction 19 (SD19) to Pay.UK. This directs Pay.UK to create and propose to the PSR their plans for an effective compliance monitoring regime. Pay.UK is responsible for monitoring all directed payment service providers’ (PSPs) compliance with the FPS reimbursement rules.
  • Specific Direction 20 (SD20) to directed PSPs. This contains the reimbursement requirement and directs in scope PSPs to comply with the reimbursement rules. 

The start date for the reimbursement policy is 7 October 2024.

Previously, the PSR issued a consultation in which it consulted on the proposed data and information that PSPs will be required to provide Pay.UK to enable it to fulfil its compliance monitoring role, and for the PSR to monitor compliance with the legal instruments. In PS24/3 the PSR confirms its requirements and responds on points raised by respondents.

In particular, the PSR confirms in PS24/3:

  • The requirement for directed PSPs to register with Pay.UK by 20 August 2024. This is one way that PSPs will identify themselves as in-scope of the policy to Pay.UK and will help facilitate a shared directory – the FPS Reimbursement Directory. This directory will enable PSPs to find one another’s contact details so that they can meet the requirements in the FPS reimbursement rules and the PSR’s policy and communicate in respect of FPS APP scam claims received.
  • The data under reporting standard ‘A’ that sending PSPs in-scope of the policy are required to retain and report to Pay.UK monthly in respect of transactions they have sent, to enable it to effectively monitor compliance with the FPS reimbursement rules.
  • The reasonable limits the PSR is placing on Pay.UK in respect of the use and disclosure of the compliance data it receives.
  • The PSR’s approach to requiring PSPs to inform consumers of their rights under the policy.
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These changes will be delivered through amendments to the Faster Payments APP scams legal instruments SD19 and SD20 (including the compliance data reporting standard) and SR1.

The PSR also confirms in PS24/3 that it is not putting in place any requirements for in-scope PSPs to comply with Pay.UK’s FPS rule to use the reimbursement claim management system (RCMS). It remains the PSR’s provisional view that the RCMS will enable firms to efficiently manage APP scam claims, and it will reconsult on whether to require use of the RCMS and the timing options should it proceed, in late 2024.