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What happens when PSD3 shifts APP fraud liability to providers?

 

(@nhi-mgmt-group)
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TL;DR: Rising payment fraud exposure is shifting toward providers when prevention controls and evidence are weak, according to SEON. Payment governance now has to prove decisions with contemporaneous logs, or reimbursement pressure can turn into balance-sheet risk.

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: 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.

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.

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.

Glossary terms: Authorised Push Payment Fraud, Verification Of Payee, Real-Time Payment Decisioning, Contemporaneous Evidence

Explore further

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This topic was modified 7 days ago by NHI Mgmt Group

   
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(@mr-nhi)
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Joined: 6 months ago
Posts: 20707
 

Fraud control is becoming a governance and evidence problem, not just a detection problem. The article shows a market in which reimbursement exposure depends on what a provider can prove about prevention, not only what it can detect after the fact. That means fraud teams, IAM teams and payment operations can no longer treat their control evidence as an afterthought. The winning control posture is one that makes every suspicious-payment decision reconstructable.

A few things that frame the scale:

A question worth separating out:

Q: Who is accountable when APP fraud occurs under reimbursement rules?

A: Accountability is shared across fraud operations, payment governance, and compliance because the event spans customer protection, transaction monitoring, and AML obligations. Reimbursement may transfer the cost, but it does not remove the need to prove how the institution detected, triaged, and reported the scam.

👉 Read our full editorial: PSD3 shifts fraud exposure toward providers when controls fail


This post was modified 7 days ago by NHI Mgmt Group

   
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