Skip to content

PSR publish APP fraud performance data

What has happened? 

In October 2023, the Payment Services Regulator published 2022 performance data (available at covering:

  • the reimbursement of fraud victims, from the largest 14 banking groups,
  • how much money is sent from each payment firm as a result of APP fraud, from the largest 14 banking groups, and
  • how much money is received by each payment firm as a result of APP fraud, for all payment firms in the UK.  

What are the key points from this data?

The data includes the UK’s 14 largest banking groups, together with the data for nine other smaller firms that were in the top 20 highest receivers of fraud. 

The percentage of total APP fraud losses by value that were reimbursed to consumers in 2022 varied from 91% for TSB down to 10% for Allied Irish Bank and by volume it varied, for full reimbursement, from 94% for the TSB down to 6% for Monzo Bank.

The average figure for customer losses, per million pounds sent, varied from £348 for TSB down to £23 for Allied Irish Bank.

Other key points highlighted by the report were;

  • that inconsistent outcomes are experienced by customers who report APP fraud to their PSP,
  • receiving fraud data shows a high degree of variation and highlights weak controls that fraudsters have exploited,
  • firms have started to address gaps in controls, but more needs to be done.

The PSR has adopted a multi-pronged approach to tackling APP fraud across payment systems. It has undertaken to monitor the performance of all firms through the data collected and it will work with the FCA to address any poor performance through targeted action plans which will help drive better outcomes for consumers. The FCA has made it a business plan priority to stop the increase in APP fraud.

The PSR will introduce a new mandatory reimbursement requirement in 2024. The central proposal is that mandatory reimbursement obligations will apply to all APP fraud cases above a minimum threshold of £100 at most – PSPs would be able to apply a lower threshold if they wish – except for cases where customers are involved in the APP fraud or have acted with gross negligence.

Also, the PSR expects PSPs to implement the capability for intelligence sharing in Q1 2024.

It is also confirmed that by October 2024, nearly all consumer payments will be covered by the Confirmation of Payee (CoP) system.

Thistle's view

Our conclusion from the PSR report is that newer and smaller payments firms and Banking as a Service firms (with smaller firms as agents/distributors) typically experience more APP fraud than more established banks. There is also a level of inconsistency in terms of reimbursement, with some firms performing higher than others in reimbursing victims. This is expected to change when mandatory reimbursement is applied next year to a wider scope of payments firms.

How can we help you? 

Thistle Initiatives has supported payments firms for over 10 years as a trusted compliance and regulatory advisor. In addition to assisting you as-and-when, our team of specialists can serve as your right hand in meeting and complying with FCA regulations. We understand the importance of staying up-to-date and compliant and are dedicated to providing the guidance and support needed to do so.

Are you looking for help with your payment fraud or other financial crime arrangements, or more general regulatory questions? Contact our specialist team now to schedule a free consultation. Get in touch with us by calling 020 7436 0630 or sending an email to