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On July 12, 2024, the Payment Systems Regulator (PSR) published听. The PS follows the PSR鈥檚 April 2024听 for all payment services providers (PSPs) in scope of the reimbursement requirement policy to report data and information to Pay.UK, so as to allow it to effectively monitor and manage compliance with the FPS reimbursement rules.听
The bigger picture
In December 2023, the PSR published听 to implement it, which set the final detailed parameters of the reimbursement requirement policy and confirmed the听commencement of the policy from October 7, 2024.听
On July 12, 2024, the PSR also published amendments to the three legal instruments:
- : Directing Pay.UK to create and propose its plans for an effective compliance monitoring regime for APP scams reimbursement ().听听
- , (): Containing the APP scams reimbursement requirement and directing in-scope PSPs to comply with the reimbursement rules ().听听
- : Requiring Pay.UK to create the APP scams reimbursement rules ().听
This regulatory influencer focuses on PS24/3 and is part of a series that will follow the development of APP fraud reimbursement, including more details on the changes made to the legal instruments mentioned above.听
For an overview of the reimbursement requirements, see the 鈥渂igger picture鈥 paragraph of听91天堂原創鈥檚 regulatory influencer听published in June, 鈥淧SR's Letter to FPS Participants Ahead of APP Scams Reimbursement Requirement Entering into Force in the UK鈥.
Why should you care?
PS24/3 confirms:听
- The requirement for directed PSPs to register with Pay.UK by August 20, 2024.听Pay.UK has procured a Reimbursement Claim Management System (RCMS), a directory to enable firms to communicate with each other and manage APP scam claims. It will further allow firms to report data to Pay.UK so it can monitor and manage firms鈥 compliance with its听.听
- The听data under听 that sending PSPs in scope of the policy are required to keep and听report to Pay.UK monthly in respect of transactions they have sent.听The first report must be submitted to Pay.UK on January 6, 2025, and cover the period from October 7 to November 30, 2024.
- The听use by Pay.UK of the data it receives must be limited for it to fulfil its functions under SD19.
- The PSR鈥檚 approach to requiring PSPs:
- To inform consumers of their rights under the reimbursement requirement, and of upcoming contractual changes听by听October 7, 2024. The PSR will publish more information to support directed PSPs later in July 2024.
- To amend their contractual terms and conditions if they provide a relevant account to consumers. The amendments must be implemented by April 9, 2025, to include a provision that a PSP would reimburse its consumers under the reimbursement requirement and rules.
In terms of听next steps, the requirements mentioned above may require significant changes for PSPs from an operational standpoint. For example, to comply, PSPs will need to adjust their consumer communication strategies, as well as their internal processes, to ensure timely and accurate reporting to Pay.UK.
Additionally, the PSR asks PSPs to continue to engage with the PSR and Pay.UK to ensure the implementation of the rules and deliver good outcomes for consumers.听
In Autumn 2024, the PSR intends to consult on proposals to require all PSPs to use a single system for FPS APP scams claim management, communication and data reporting, and听. It is, therefore, recommended that PSPs participate in the upcoming consultation process.
