APP fraud reimbursement decided on time, the same way by every handler, with half recovered
Every scam claim decided on time, the same way by every handler, with half recovered.
See one case, screen by screen ↓APP fraud reimbursement is the UK requirement, in force since October 7, 2024, that a bank sending a Faster Payment reimburse a customer tricked into paying a scammer, up to £85,000, within five business days, and claim 50% from the receiving firm. APP Fraud Reimbursement is the solution that runs those claims: agents answer each of five gates with the evidence and the PSR rule, a claims handler decides, a second person checks the release, and the receiving firm's half is claimed as the refund posts.
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APP fraud reimbursement has been mandatory in the UK since October 7, 2024: a bank that sends a Faster Payment must reimburse a customer tricked into paying a scammer, up to £85,000 a claim, within five business days, and may then claim half from the bank that received the money. The rule leaves the judgment to the sending bank. Was the payment in scope? Did the customer act with gross negligence against the consumer standard of caution? Were they vulnerable? How much is paid, and how is the receiving firm's 50% claimed?
Today a claims handler answers those questions from scattered records: the payments in one system, the warnings the customer saw in the fraud system, a 2024 note in the core banking system, call recordings nobody has time to replay, and a policy PDF. A generic warning gets counted as an intervention, although the PSR's guidance says interventions must be consumer, scam and transaction specific and the burden of proof is the bank's. A vulnerability recorded two years ago is missed, and the £100 excess is taken. The receiving firm's half is claimed days late, or calculated without the excess rule. Across UK firms, reimbursement rates in the first year ranged from 21% to 94%.
Estimated split of the people's working time on one APP scam claim, by hand and with the solution. It leaves out the waiting for the customer and the receiving firm, which the five-business-day clock still counts.
Seven agents answer five gates with the rule; the handler decides and a second person checks.
Edith Carraway, 74, a customer of Corvane Bank UK, sent six Faster Payments, £11,750 in all, to a man she met online who called himself Jonathan Marlowe. Here is her APP scam reimbursement claim, CLM-2026-48213, screen by screen in the working solution.
Mrs. Carraway calls with her daughter Clare, three days after her last payment. The Intake agent opens the claim at 9:14 a.m. with all six payments, £850 to £3,000, to “J MARLOWE” at Wendmere Bank, starts the five-business-day clock and notifies Wendmere Bank through the industry claims exchange at 10:31 a.m., inside the two-hour rule. Wendmere answers on Tuesday: the account was opened Aug 27, £9,610 moved out within hours, £2,140 is frozen.
Confirmation of Payee on the first payment: “match”. A match says the name is right, not that the person is who they claim to be.
Gate 1 is answered in scope at 0.98: a consumer, Faster Payments between UK accounts, reported within 13 months, under the £85,000 cap. For the consumer standard of caution the agent tests all four requirements. The two warnings she saw were the generic in-app text for “paying a friend or family member” and the fraud team's general call script, so neither can support gross negligence. She reported promptly, answered nine of nine questions and consented to a police report, PR-2610-55821.
PSR guidance: interventions “must be consumer, scam, and transaction specific. They should not consist of ‘boilerplate’ written warnings.”
The Vulnerability agent read 14 notes and 4 call transcripts and found three signals: an April 2024 note that her husband had died and she lives alone, her own words on the Oct 16 call, and her request for large-print letters. It mapped them to the FCA drivers and proposed a material impact at 0.88. Moira spoke with Mrs. Carraway and her daughter for 25 minutes and confirmed it.
From the Oct 16 call: “he's been such a comfort since Arthur passed”. Age 74 is listed as not counted.
Six customers are on Moira's list. Patricia Oduya's signal, a hospital stay in September quoted from an Oct 14 call, scores 0.74, below the 0.85 threshold, so the agent asks rather than proposes. Her clock is stopped for a permitted purpose while a call is booked for Friday at 10:30 a.m. Moira must add a note before she can confirm or decline.
The Vulnerability agent never labels a customer vulnerable on its own.
Leah opens the claim as five gates under the clock: due Mon Oct 26, with the 35th-business-day long stop on Mon Dec 7. Gates 1 to 3 are answered, each with its confidence and the PSR passage it rests on. Gate 4 proposes £11,750 with the £100 excess waived, because a vulnerable customer may not be charged one. At 9:58 a.m. the Consistency agent found six similar decided claims, all reimbursed in full.
Specific Requirement 1, 5.21: “PSPs may not apply a claim excess if the victim was a vulnerable consumer.”
Leah approves on day 3 of 5. She could change the amount or refuse with a reason code, and either would go to a second person. Priya Venkatesan, Claims Quality Reviewer, checks the amount, the account and the letter at 10:12 a.m. £11,750 is credited to the account ending 4471 and posted to the general ledger.
Money never moves on one person's word.
The outcome letter opens with the refund, then says nothing was taken off, what happened and why, what to watch for, and that she may refer a complaint to the Financial Ombudsman Service within six months. Seven checks pass, including reading age 9 at 214 words. It goes by first-class post in large print, the format on her record.
“We are refunding the £11,750 you lost.”
Once the refund posts, the Recovery agent claims half from Wendmere Bank through the claims exchange, due within five business days, by Thu Oct 29. No excess deduction: the excess was barred by her vulnerability, not chosen. If the frozen £2,140 comes back, it is split under the rule. Across the team, £318,475 is outstanding on 119 claims, and overdue contributions are chased in bulk.
PSR: the sending firm “cannot request this contribution unless and until they have reimbursed the consumer.”
Owen Tallis lost £34,200 to an investment scam. Before payments 2 and 3 he saw a bespoke warning naming crypto investment scams and was told in branch it was “very likely a scam”; he said the money was for a kitchen fitter. The proposal reimburses payment 1 less the £100 excess, £3,900, and refuses £30,200. Over £30,000 and a refusal: Priya reads the burden-of-proof checks and the Consistency agent's 11 similar claims before she approves or returns it.
The Assessment agent never refuses: a refusal is only ever a proposal for the handler.
1,342 claims, 82.4% reimbursed by value, 100% decided on time, £1.69 million recovered of £1.72 million due. The spread between handlers is 6.1 points against an aim of 5. The Consistency agent traced it to the excess: applied on 11 claims where a vulnerability was later confirmed. The 11 refunds of £100 are drafted, each needing a release check.
The same claims, seen by the four people who carry them: what their week looked like, and what it looks like now.
Seven agents answer five gates with the rule; the handler decides and a second person checks.
Builds the claim from the customer's report: the payments, the customer and each receiving firm. Starts the clock and notifies every receiving firm within two hours through the industry claims exchange.
Answers the scope tests, the four requirements of the consumer standard of caution and the proposed amount, and classes every warning and call the customer received as bespoke or boilerplate, quoted word for word.
Reads customer notes and call transcripts for Consumer Duty signals, quotes each one with its source, maps them to the FCA drivers (health, life events, resilience, capability) and proposes whether they had a material impact.
Counts five business days from the report, records each stop of the clock with its permitted purpose, watches the 35th-business-day long stop and raises the day-4 alerts.
Compares each proposal with similar decided claims before anyone signs, flags an outlier, and reports the spread between handlers to the Head of Fraud Operations.
Writes the outcome letter in plain language with the reasons and the Ombudsman referral rights, in the format the customer needs, and checks the reading age.
Computes each receiving firm's 50%, pro rata across firms and with the excess rule, claims it as the refund posts, tracks the five-business-day contribution clock, chases in bulk, answers claims against the bank and splits returned funds.
Decides; a reviewer checks the release. The agents propose; a named person decides.
Ask about a claim, a gate, a clock or a recovery, or say what to prepare next. Every answer cites the record and the rule.
Why is no excess taken from Edith Carraway's refund?
Because she was vulnerable when she paid, and it had a material impact on her ability to protect herself: no excess may be applied, and the caution exception cannot apply. The signal is the April 2024 bereavement note, confirmed by Moira Callander yesterday at 4:05 p.m.
Which of my claims are due today?
Two, both on day 5 of 5: Graham Whitlow, £8,900, waiting for Priya Venkatesan's release check, and Derek Ashworth, £1,600, ready for your decision. Three more are stopped, each with its 35th-business-day long stop.
Build the September pack for the PSR and FCA
Building it from the audit trail: 1,342 claims with their decisions and reasons, the stop-the-clock log with each permitted purpose, vulnerability outcomes, contributions claimed and paid, every letter, and the agent and prompt versions. Customer account numbers are masked to the last four.
13 screens from the working solution, on its sample data. Pick one to see it large.
The limits every claim is checked against are settings, changed only with a second administrator's approval and kept on the record.
| Setting | Default | Choose from |
|---|---|---|
| Second review threshold | £30,000 | Claims over this amount get a full second review |
| Refusals on gross negligence | Always a full second review | Fixed: every refusal is read twice |
| Release check | Every release | A second person on every reimbursement, refusal letter and payment out |
| Excess | £100, except vulnerable | Never · above £1,000 · always except vulnerable |
| Receiving firm's share when the excess is barred | Full 50% | Full 50% · deduct £50 |
| Gate answers needing a person | Below 0.85 confidence | Marked “needs your judgment” |
| Clocks | 5 · 35 business days | UK bank holidays · day-4 alert at 9:00 a.m. · two-hour notice to receiving firms |
| Letters | Reading age 9 or lower | Large print · braille · audio · email, from the customer's recorded needs |
Every figure is labelled: a target the solution is built to, an estimate, a typical published result, or a proven one.
“demo” = seen in the working solution, on its sample claims · “target” = the design goal, measured in the live solution · “estimated” = our estimate · “typical” = published figures (the PSR's evaluation of the reimbursement requirement's first year, July 2026: firm reimbursement rates of 21% to 94%, reimbursement by value up from 54% to 65%, about £173 million returned, one firm applying the consumer standard of caution exception in over 25% of cases by value; the rules from PSR PS25/5 and Specific Requirement 1). Corvane Bank UK, Wendmere Bank, the customers, the people, sort codes and account numbers named on this page are fictional: characters and sample data in the working solution.
APP fraud reimbursement is the UK requirement, in force since October 7, 2024, that a bank sending a Faster Payment reimburse a customer tricked into paying a scammer, up to £85,000, within five business days, and claim 50% from the receiving firm. APP Fraud Reimbursement is the solution that runs those claims: agents answer each of five gates with the evidence and the PSR rule, a claims handler decides, a second person checks the release, and the receiving firm's half is claimed as the refund posts.
Five business days from the report. The clock may be stopped only to wait for information for a permitted purpose, and the claim must still close before the end of the 35th business day. In the solution every stop needs a reviewer's approval, the long stop is always shown, and the handler is alerted on day 4.
Only when the customer failed the consumer standard of caution with gross negligence, which the bank must prove. The Assessment agent quotes every warning and call and classes each as bespoke or boilerplate, because only a consumer, scam and transaction specific intervention can support that finding. A refusal is a proposal for the handler, and every refusal on gross negligence gets a full second review.
No. Where a vulnerability had a material impact on the customer's ability to protect themselves, no excess may be taken and the caution exception cannot apply. The Vulnerability agent finds the signals in notes and call transcripts and proposes; a vulnerable customer specialist confirms or declines with a note. Age alone is never a signal.
Once the refund posts, the Recovery agent claims half from each receiving firm through the industry claims exchange, pro rata when there are several and with the excess rule applied. It tracks the five business days the firm has to pay, chases overdue contributions in bulk, answers claims against the bank with a second person on every payment out, and splits any returned funds.
No. The agents never refuse, never send a letter, never stop a clock and never move money. The claims handler decides, a second person checks every release, refusals on gross negligence and claims over £30,000 get a full second review, and every override is recorded with a reason code.
Yes. Every action by people and agents is on the audit trail with who, what, when, why and the evidence. An export pack is built for a PSR and FCA request, an internal audit sample or a Financial Ombudsman case file, with account numbers masked to the last four. Suspicion reports stay with the MLRO's team and never reach a customer-facing view or letter.
The Agentic Solution Engine builds and deploys it from your requirements and documents: your reimbursement policy, reason codes, letter templates and the systems your claims run on. It goes live once every quality gate has passed.
Each request reaches the beneficiary bank in minutes, while there is money to freeze.
1-min demoFirst-Party Fraud DetectionFalse claims denied on the evidence, and no genuine victim denied.
1-min demoReg E Dispute ManagementEvery claim on its legal clock, provisional credit by day 3, every letter checked.
1-min demoWe'll run APP Fraud Reimbursement on a sample of your own past APP scam claims.