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APPR FAQs – RCMS registration and directory set up

Access to the Faster Payments System (FPS) reimbursement directory containing all registered in-scope payment service providers (PSPs) and their contact details will be provided to PSPs who have:

Step 1 – Registered as in scope of SD20 online at www.wearepay.uk/appr

Step 2 – Passed the identification and verification (ID&V) process

Step 3 – Received and then signed the reimbursement claims management systems (RCMS) contract.

This will enable communication between PSPs for claims management purposes.

The directory will provide a routing service to enable sending PSPs to accurately and reliably route an authorised push payment (APP) fraud claim to the correct receiving PSP. This will use the sort code and account number provided by the victim to the sending PSP, when they report the APP fraud claim.

The FPS reimbursement directory is based on data from the following sources, stored within the RCMS:

  1. The PSP record – This includes the PSP’s name, contact information and details of their suspense account where they wish the receiving PSP to send their reimbursement contribution amount (via the Faster Payment System (FPS)).
  2. The extended industry sort code directory (EISCD) – This is an extract of Pay.UK’s central database of all PSP sort codes that are addressable within the FPS.
  3. The ‘override table’ – This is a database of that have been registered to the EISCD via the RCMS solution. This refers to a sponsored PSP that is not directly visible on the EISCD and which has registered their use of a sort code by raising a sort code override request within the RCMS.


When a RCMS Core + Claims user raises a claim via the RCMS, the RCMS solution will automatically route the claim to the relevant responsible receiving PSP, using the specific sort code/account information that is recorded in the FPS reimbursement directory at the time the suspected fraudulent payment was made.

When a RCMS core user is either the sending or receiving PSP, they will need to do a manual search of the FPS reimbursement directory by using the search screen user interface (UI). This will enable them to retrieve the relevant contact details in order to process their claim outside of the RCMS.

The FPS reimbursement directory will support Directed PSPs with a register of accurate data of sort codes and account numbers (and where required, secondary reference data).

By default, data at sort code level will be provided to the direct PSP where they are identifiable using EISCD. This default data will be linked from the owning bank registered on the Pay.UK bank reference data (BRD) service and will be published through the EISCD.

Within Pay.UK’s BRD service, each PSP registered as an FPS direct participant or an FPS indirect participant in the FPS is allocated an owning bank code, under which the sort codes used by that PSP, are registered.

Using this default option, the owning bank of the sort code to where the Faster Payment transaction (to which the claim relates) was sent, will be the point to where the APP claim is sent.

This default option may result in APP claims being routed incorrectly where the sort codes of the sort code owning PSP have been provided to other Directed PSPs under an FPS indirect access model/agreement. Recognising that this challenge and the fact that a large number of Directed PSPs are not registered in Pay.UK’s BRD service, an override to the default routing option has been created for either sort code level, or sort code/account number level.

For example:

  • Bank A is the owner of the sort code and provides it to Bank B under FPS indirect access arrangements. Both are Directed PSPs in scope of SD20. Both have completed the necessary steps to have access to the RCMS and are ready to set up and register their sort codes
  • When setting up on the directory, Bank B can initiate an override for the sort code that Bank A provides. This override ensures that Bank B secures the sortcode so that it appears in Bank B’s Directory entry and so that claims are routed to Bank B (not Bank A)
  • Bank A then receives a notification in RCMS to confirm that Bank B is the rightful users of the sort code. If Bank B is the rightful user then Bank A confirms this (if not Bank A can reject it),. This completes the process of Bank B gaining the sort codes that it uses in their Directory entry to ensure all claims are directed to them.


When a Directed PSP that is a FPS direct participant provided FPS indirect access arrangements to another Directed PSPs that allow for more than one Directed PSP to use the same sort code (co-mingled), then the FPS reimbursement directory registration process will not permit more than one PSP to override a sort code. In these circumstances the sort code alone is insufficient to accurately route the claim and the account number, and/or secondary reference data will need to be registered to ‘qualify’ the sort code to link to one or more Directed PSPs.

Additionally, a sort code or sort code/account number combination can be marked as out of scope where the sort code is accessible via the FPS but is out of scope for SD20. For example, where a sort code is registered in the Crown Dependencies (Jersey, Guernsey, and Isle of Man) or Gibraltar.

When routing a claim using the RCMS Core + Claims, the system will first check the account details in the claim to identify whether there is a sort code and/or account number exception. If not, the system will then check whether there is a sort code override, and if not, the bank code will be used as the default option.

APP reimbursement directory: Registration and data population – Dos and don’ts

This is a short guide intended for use by Pay.UK and for Directed PSPs that are registering for and populating the APP reimbursement directory with their content to enable accurate routing of APP claims between sending and receiving PSPs.

Take the first step of registering as in scope of SD20 (as a directed PSP) via www.wearepay.uk/appr. This applies even if your PSP is not listed on the Payment Systems Regulator’s (PSR) website (as detailed on the page called “Faster Payments System participants potentially in scope of our Specific Direction 20”).  As shown above, this is the first step in gaining access to the FPS reimbursement directory.
Actively take out of scope the sort codes that belong to you but are not in scope of APP reimbursement when setting up an account on the FPS reimbursement directory. For example, sort codes, whose based branches are in Jersey, Guernsey, Isle of Man and Gibraltar.
Consider if it is likely that your sort code is used by one or more other PSPs (for example, if they are co-mingled – further details below). Where you do have a co-mingled sort code you must also provide account numbers or secondary reference data of the underlying relevant accounts (see details below).
Ask your provider of indirect access to advise whether your sort code is shared (co-mingled) with other PSPs that may also be in scope of APP reimbursement.
Consider whether you, as a directed PSP, have issued your customers with virtual account numbers or other arrangements that may prevent clear identification of the PSP from the account information the sending PSP consumer would use to make payments to your clients/customers. If you are concerned about this, ensure you ask your provider of indirect access to advise you.
Consider whether you have any clients/customers to which you provide payment accounts that fit the definition of a consumer.
Consider whether your consumer accounts are identified by account numbers that are not eight numeric digits, such as building society roll numbers. This may mean that you need register secondary reference data to ensure accurate routing of claims, particularly if you have a head office collection account (HOCA) structure.
Include sort codes that are not linked to your relevant accounts, such as those that are provided to, and used by another PSP under a commercial or other agreement with you.  This applies to the provision of sort codes on the online registration and when registering your sort codes in the FPS reimbursement directory.
Include sort codes of any other PSP, other than if you are registering a legal entity group structure that contains within its scope Directed PSPs. This applies to the provision of sort codes on the online registration and when registering your sort codes in the FPS reimbursement directory.
Rely on Pay.UK to register sort codes in the FPS reimbursement directory for you. When you set up your FPS reimbursement directory entry you will be viewing sort codes that have been copied across from the EISCD (not sort codes that you may have provided on the online registration form), and that data is unlikely to be accurate for APP claim routing. This is because that data will contain quantities of sort codes that are not linked to relevant accounts. This may result in claims being incorrectly routed to you that should be for one of your PSP clients, or to an account that is, for instance, geographically out of scope (see below).
 

FAQs

The reimbursement claims management system (RCMS) will be pre-populated with the extended industry sort code directory (EISCD). As outlined in this document, all payment service providers (PSPs) must check their sort codes in the Faster Payment System (FPS) reimbursement directory as part of their initial set up.  Due to market innovation and commercial constructs, not every PSP is shown in the EISCD as they have a range of sponsored sort code arrangements which do not cause them to be registered in the EISCD. Therefore, at registration, we ask that PSPs who are not listed on the EISCD to provide the sort codes and/or account numbers that they make use of in a sponsored arrangement. PSPs that are listed on the EISCD are not compelled to provide their sort codes at the point of registration and we appreciate the good corporate citizenship of EISCD listed PSPs who do, and update them on the FPS reimbursement directory as part of their set up.

The preferred and simplest option is for each payment service provider (PSP) to register their separate entities independently of each other.  This results in a separate reimbursement claims management system (RCMS) platform for each entity, making traceability easier for compliance monitoring. However, we recognise that some PSPs manage all of their corporate entities under one operational umbrella, and some manage brands within the same corporate entity separately, so we are flexible in accepting PSPs to register at the group, corporate entity, or brand level. While more complex, compliance monitoring is still possible with these flexible options.  The main thing to remember is that each registration flows into its own RCMS contract/product and creates separate directory entries.

No, each directory entry will have only one reimbursement account listed.  Payment service providers (PSPs) can use internal reconciliation processes to manage this or take advantage of the flexibility we are offering regarding registration of groups, legal entities and brands.

No, this information is mandatory and will be included in your directory entry. Payment Service providers (PSPs) can make use of interactive voice response (IVR) or simple recorded messages where your preference is to receive claims only by email channel.

Yes, this is possible.  Firstly, the entity that registers as in scope of SD20, and that contracts to take up the RCMS product, must be the in-scope payment service provider (PSP) as the PSP is accountable for compliance and performance against the policy requirements.  Legally, your outsourced partner will be a supplier to your organisation and in the reimbursement claims management system (RCMS) contract your organisation is liable for their performance and compliance with the system and rules. When you register for the RCMS, please specify super users/service administrators from your own organisation. This will ensure that your organisation maintains overall control of the RCMS. When super user/service administrator receives the activation email, they can then add users in other roles from your outsourced supplier organisation to do the day-to-day work on the RCMS.

Once you have contracted to either reimbursement claims management system (RCMS) Core or RCMS Core + Claims you will receive an activation email (after 2 September 2024) inviting you to set up an account on the RCMS. As part of this set up you can view your directory entry.  As you don’t have your own sort codes, you will need to enter the sort codes (and if using shared sort codes, account numbers too) that you have use of, from your sponsor.  Once you do this the system will automatically notify the sort code sponsor of your request, and they can confirm that these are sort codes that your firm (their sponsee) uses. This will complete the allocation to you. Self-serve training information will be available on the RCMS platform.

If your sponsor has not yet activated an account, they will not be able to approve your sort code request.  Pay.UK is working closely with Indirect Access Providers (s) to ensure that they are set up in good time.  We encourage IAPs and their sponsored clients to work closely together on this important industry policy and initiative.

Yes, this is what will happen if your indirect participant client doesn’t activate an account on the reimbursement claims management system (RCMS) platform. If they have registered but not activated their account, both you, as their supplier, and Pay.UK will have some information about them and be able to contact them. If they have not registered at all, Pay.UK will have limited ability to reach them. We are providing supporting materials to IAPs to encourage their indirect participant clients to register, contract and activate an account. We are also contacting all potentially in-scope payment service providers (PSPs) through our own engagement campaigns. Additionally, registration is made mandatory by the Payment Systems Regulator (PSR) for all PSPs operating relevant accounts that use FPS for payments, by 20 August 2024.

Yes, there are two ways to mark sort codes as out of scope:

  1. If you have determined that your organisation is not in scope of SD20, we request that you please email CBDO@wearepay.co.uktitled “Not in scope” with your contact details. We will then contact you with details of a process that includes providing us with your out-of-scope sort codes. When we pre-populate the Faster Payment System (FPS) reimbursement directory, we will mark the relevant sort codes as out of scope.  They will show as “inactive” in the search results in the directory. Please note, if claims are raised on these sort codes, your payment service provider (PSP) could be in breach of the authorised push payment (APP) reimbursement policy.
  2. If you have some sort codes that are out of scope but your PSP is in scope and has been set up on the reimbursement claims management system (RCMS), you can mark these sort codes as out of scope when you set up an account on the RCMS .  Self-serve training information will also be available on the RCMS platform.

All payment service providers (PSPs) who register as in scope of SD20 and pass the identification and verification (ID&V) process will be given secure access to detailed training, and operational and technical information. Please register for the reimbursement claims management system (RCMS) at www.wearepay.uk/appr by 20 August 2024 as required by the SD20 legal instrument,  and to get access to these important RCMS materials.

Frequently asked questions (FAQs)
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