Introductory Q&As
What is the APP Reimbursement policy?
The Authorised Push Payment (APP) Reimbursement Policy is a legal requirement from the Payment Systems Regulator (PSR) which relates to us (Pay.UK) and in-scope payment service providers (PSPs).
All in-scope PSPs which can send or receive payments via the Faster Payments Scheme (FPS), are required to reimburse eligible consumers within five working days, and to share the cost of the fraud loss equally between sending and receiving PSPs.
The policy aims to improve consumer experience and protection for end users in cases where they are victims of fraud.
What is an in-scope PSP?
An in-scope PSP participates in the FPS, either directly or indirectly through another business, to which Specific Direction 20 (FPS APP scam reimbursement requirement) applies and provides relevant accounts held in the UK.
What is a direct PSP?
A direct PSP has direct access to the FPS.
What is an indirect PSP?
An indirect PSP accesses the FPS, to make or send payments on behalf of its customers, through an agreement/arrangement with another PSP. The indirect PSP is enabled, through the direct PSP, to provide services to its customers using the FPS.
How does my PSP register for APP Reimbursement?
Registration is now live on the Pay.UK website. Click here to access the how to guide to registration.
Deadline for PSPs to register is expected to be 20 August 2024, subject to the PSR’s consultation outcome.
If we don’t have any APP claims, do we need to report anything?
Yes, you are still required to report a nil return for each relevant reporting month under the PSR’s Specific Direction 20 Compliance Data Reporting Standards (CDRS), from 7 October 2024 (reporting standard A) until the time businesses move to Reporting Standard B. This date is currently 1 May 2025 but is subject to the PSR’s consultation outcome.
Once all in-scope PSPs are using the Reimbursement Claims Management System (RCMS) for claims management, PSPs will not need to report any data as this will be recorded in near real time under Reporting Standard B).
Can we wait until the business gets its first claim to register?
In-scope PSPs must not wait until their first claim to register. Deadline for registration is expected to be 20 August 2024, subject to the PSR’s consultation outcome.
All in-scope PSPs, whether they are direct or indirect, must have registered with Pay.UK (the FPS operator) for the purpose of reporting data and compliance monitoring and management.
Registration is an important part of implementation, for example, it allows us to build the directory so businesses can contact one another if sending and to be contacted if receiving.
How much will it cost my PSP?
We are not charging PSPs to use the RCMS in 2024. An annual rate card will be published in November 2024 for commencement in January 2025. In the meantime, we will publish draft pricing and the pricing model for 2025 before the RCMS contracts are issued to customers, in July 2024.
How do I know what claims are in-scope of the APP Reimbursement policy?
In-scope APP claims are any payments (from 7 October 2024) which have been authorised by a consumer within the preceding 13 months and have all of the following features:
- It is executed through the FPS
- It is authorised by a PSP’s consumer
- It is executed by a PSP in the UK
- The payment is received in a relevant account in the UK that is not controlled by the consumer (a controlled account is defined as an account that a consumer can access and make payments from).