PSD3 and payment fraud: what changes for providers now?

TL;DR: EU payment users absorbed about 85% of credit-transfer fraud losses in 2024, according to SEON, but the PSR and PSD3 political agreement shifts more liability toward payment providers when fraud-prevention controls are missing or weak. That makes fraud governance, evidence retention and real-time decisioning a balance-sheet issue, not just a compliance one.

Editorial analysis by NHI Mgmt Group, based on content published by SEON: “The EU Has Repriced Payment Fraud, and the Bill Lands in the Boardroom”.

By the numbers:

• In 2024, payment service users absorbed approximately 85% of credit-transfer fraud losses in the European Economic Area.
• The EBA and ECB recorded €4.2 billion in payment fraud across the EEA in 2024.
• Credit-transfer fraud accounted for €2.2 billion of the EEA’s 2024 payment fraud total.

Key questions

Q: What breaks when payment fraud controls rely only on the transaction itself?

A: Controls fail when they treat the payment as isolated from the actor behind it.

Q: When should organisations prioritise real-time fraud monitoring over batch reviews?

A: Organisations should prioritise real-time fraud monitoring whenever compromise can quickly become monetary loss, such as account takeover, instant payments, or onboarding abuse.

Q: What are the signs that payment fraud decisioning is failing?

A: Common signs include a high share of disputes after settlement, repeated losses from the same scam typology, weak or missing decision logs, and inconsistent responses to similar risk scores.

Practitioner guidance

• Define fraud as a balance-sheet risk Set explicit risk appetite, loss thresholds and executive ownership for authorised-payment fraud, then report them alongside other material financial risks.
• Add real-time context to payment decisioning Use device, recipient, behaviour and journey signals to classify transfers before execution, especially where a first-time payee or unusual path appears.
• Instrument every allow, warn, delay and freeze decision Store the signals used, the action chosen and the rationale inside the payment flow so complaints and reimbursement reviews have contemporaneous evidence.

Bottom line: The article’s central risk is a shift in fraud liability from the customer toward the provider when prevention controls are absent or ineffective.

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