A&O Shearman | FinReg | UK Payment Systems Regulator Writes to Payment Firms on Implementation of Authorized Push Payment Scams Reimbursement Requirements
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  • UK Payment Systems Regulator Writes to Payment Firms on Implementation of Authorized Push Payment Scams Reimbursement Requirements

    May 24, 2024
    The Payment Systems Regulator has published a letter it sent to payment service providers on the new authorized push payment scams reimbursement requirement. The letter highlights three key areas where the PSR would like firms to focus their implementation activities over the coming months to ensure effective and timely implementation by October 7, 2024, when the new requirement comes into effect. The three areas of focus are:
    • Understanding the new reimbursement requirements—all PSPs participating in the FPS will need to consider whether the requirements apply to them either as a sending PSP or as a receiving PSP providing a relevant account to a service user. The requirements apply to both direct and indirect participants of the system.
    • Claim management and data reporting through Pay.UK—Pay.UK has procured a reimbursement claim management system which firms will use to communicate with each other and to manage APP scam claims, as well as to report data to Pay.UK so it can monitor and manage firms' compliance with FPS reimbursement rules. Firms have until August 20, 2024 to register with Pay.UK.
    • Consumer awareness—the PSR wants firms to be transparent in communicating the reimbursement requirements to consumers and take proactive steps to notify them of the protections available under the new reimbursement requirement.

    The PSR recently consulted on the data and information that PSPs will be required to provide to Pay.UK under the new reimbursement requirement and the manner in which it is provided, with final requirements intended to be published in July 2024 as part of the broader amendments to SD20. The letter concludes with a discussion about steps the PSR and Financial Conduct Authority are taking to establish incentives to prevent APP fraud arising in payment systems in the first place.

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