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The Payments Association has escalated pressure on ministers and regulators to confront what it describes as a structural failure at the heart of the UK’s fraud regime: the platforms where many scams begin face far less financial accountability than the banks that end up reimbursing victims.
Payments Association calls for shared liability
In a new white paper, The New Origin of APP Fraud: Digital Platforms and Shared Accountability, the trade body argues that authorised push payment fraud is now being incubated upstream, on social media, online marketplaces and messaging services, before it ever reaches the banking system.
That matters because the current reimbursement framework places the heaviest burden on payment firms, even when the original deception started elsewhere.
A fraud problem that starts before the payment
The report’s core contention is that APP fraud is rarely a point-of-payment problem in isolation.
By the time a transfer is initiated, the victim has often already been groomed through fraudulent advertising, impersonation or direct contact over a period of days or even weeks.
According to the findings, around two-thirds of reported APP fraud cases in the first half of 2025 originated on digital platforms, with Meta-owned services such as Facebook, Instagram and WhatsApp repeatedly cited as major vectors for scam exposure.
The Payments Association says this creates a serious mismatch between origin and liability: platforms enable reach and scale, while banks are left to deal with the financial aftermath.
That mismatch has become more visible since mandatory reimbursement rules were introduced for the payments sector in late 2024.
Those rules strengthened consumer protection, but they also sharpened an awkward policy question: why should banks alone carry the cost when the fraud often begins on ad-driven or messaging-led digital networks?
Why the industry wants regulation to move upstream
Riccardo Tordera-Ricchi, vice president of policy and government relations at The Payments Association, framed the issue starkly.
Banks, he argues, are being asked to catch fraud “at the bottom of a waterfall” while the source remains largely uncontrolled.
The white paper does not suggest removing obligations from financial institutions. Rather, it calls for a shared-responsibility model in which digital platforms face enforceable duties proportionate to their role in enabling scam discovery and distribution.
In practice, that would mean mandatory identity verification for advertisers, tighter monitoring of suspicious promotions, faster removal deadlines for fraudulent content and real-time intelligence-sharing between technology firms and payments providers.
The report also calls for financial consequences where platforms repeatedly fail to prevent scam exposure. That is a notable shift in tone.
Voluntary commitments and broad principles are no longer seen as sufficient by much of the payments industry, particularly as fraudsters continue to migrate seamlessly from public advertisements into encrypted or private messaging channels.
A turning point in the APP fraud debate
The broader significance of the report is political as much as operational. It pushes the fraud debate beyond reimbursement and towards prevention at source.
The Payments Association’s case is that consumer trust will not be restored simply by compensating losses after the event; the system must also disrupt the commercial and technological conditions that allow scam campaigns to flourish.
For government, the message is increasingly hard to ignore. If most APP fraud begins outside the banking perimeter, then regulation focused mainly on banks looks incomplete.
The next phase of UK fraud policy may therefore hinge on a simple principle: accountability should follow the scam to where it starts.
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