The UK’s mandatory reimbursement regime for APP scams is doing what it was designed to do — mostly. The Payment Systems Regulator’s 2026 evaluation finds that the share of confirmed losses reimbursed rose from 54% before the policy to 65% after it.
The good news. Victims who were previously refused refunds are now far more likely to recover their money, and the review estimates APP losses have fallen by around £73m a year as banks invest in prevention.
The catch. Scams routed through international payments, which fall outside the rules, rose from £21m in 2023 to £60m in 2025. Criminals follow the path of least resistance.
A regime in transition
Oversight is moving from the PSR to the Financial Conduct Authority, which is expected to consult on the next phase. Industry is lobbying for tech platforms and telecoms firms — where most scams start — to share the cost.
Banks pay for scams that begin on platforms they don’t control.
A common industry complaint
For compliance teams. Track the FCA consultation closely: changes to the £85,000 cap, the gross-negligence exception or the scope of international payments would directly affect reimbursement budgets.
Source: Payment Systems Regulator
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