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Reimbursement position since Oct 2024

5 days

Assessment and payment window

50/50

Split between sending and receiving firms

Overview

What this service is, and what it is not

Authorised push payment fraud is where you are deceived into sending money yourself, an impersonated bank official, a fake invoice from a builder, a purchase from a seller who never existed, a romance that turned out to be a fabrication. Because you pressed the buttons, banks historically treated the loss as yours.

That changed on 7 October 2024. The Payment Systems Regulator's reimbursement requirement makes reimbursement the default for in-scope APP scams sent over Faster Payments or CHAPS, split equally between the sending and receiving banks. Claims must be assessed and paid within five business days, subject to a limited ability to pause for more information.

Refusal is now the exception and has to be justified. The main ground is that the customer acted with gross negligence, a deliberately high bar, and one that cannot be applied to customers who are vulnerable. There is an excess that firms may apply and a maximum reimbursable amount, and the detail of how those are applied is exactly where claims are wrongly reduced.

We take these claims on because the refusals we see frequently misapply the standard: treating ordinary trust as gross negligence, ignoring vulnerability, or applying the excess where it should not be. If you have been declined, that decision is challengeable and the Ombudsman has been consistently willing to overturn it.

We do not offer to trace or recover cryptocurrency, and we will never contact you first. If someone approaches you claiming they can recover money you have already lost, that is the pattern of a recovery scam and you should report it.

The problem

Business challenges this addresses

Refused for gross negligence

Gross negligence means significantly more than being careless or trusting. Sophisticated impersonation is designed to deceive reasonable people, and being deceived is not negligence.

Vulnerability not taken into account

Customers who are vulnerable cannot have the excess or the gross negligence exception applied to them. Firms routinely fail to identify vulnerability at all.

The warning defence

Firms argue an on-screen warning was ignored. Generic warnings that do not address the specific scam carry much less weight than firms assume.

Told it is a civil matter

Being pointed at the police or the courts is not an assessment of your claim. The firm still owes you a reimbursement decision under the rules.

How this claim runs

How we deliver it

Every stage has a named owner on our side and a defined output. You always know what is happening and what comes next.

Typical duration: Most cases resolve in 8–16 weeks

  1. Report it first

    Contact your bank immediately and report to Action Fraud. Speed matters, funds are sometimes still recoverable. We will tell you exactly what to say.

  2. Free assessment

    We review the scam, the payment journey, the warnings shown and the reasons given for any refusal.

  3. Build the case

    The deception, why it was convincing, what the bank did or failed to do, and any vulnerability relevant to how the rules apply.

  4. Formal representation

    A written claim or complaint addressing the specific ground of refusal, with a deadline for a final response.

  5. Ombudsman

    Refusals go to the Financial Ombudsman, which has taken a consistent line on the reimbursement rules and on vulnerability.

Deliverables

What you receive

  • Immediate practical guidance on reporting, before anything else
  • A review of the payment journey and the warnings actually shown
  • A challenge to a gross negligence finding where it misapplies the standard
  • Identification and evidencing of vulnerability where relevant
  • Ombudsman referral with a full submission
  • A named case handler throughout, these cases are distressing and continuity matters
Outcomes

What changes afterwards

01

Reimbursement is now the default

The burden has shifted. Firms must justify refusing rather than assume the loss is yours.

02

Both banks share liability

Sending and receiving firms split reimbursement equally, so a claim does not depend on one firm's cooperation.

03

Vulnerability changes the outcome

Where a customer is vulnerable, the excess and the gross negligence exception cannot be applied. This is frequently overlooked.

Related work

Claims of this kind we have run

Banking and Payments 27 weeks

$19,400 reimbursed after a bank blamed the customer for an impersonation scam

The bank refused reimbursement for gross negligence. It had not identified that the customer was recently bereaved, had not asked, and its warning did not address the scam that actually…

Total recovered including interest
$22,330 Total recovered including interest
Refusals overturned
2 Refusals overturned
From referral to settlement
19 weeks From referral to settlement
Read the engagement
Questions

Frequently asked

No, that is precisely what the reimbursement rules address. Being deceived into authorising a payment is what APP fraud is, and it is now reimbursable by default.

The rules cover in-scope payments over Faster Payments and CHAPS to a UK account. Transfers to crypto exchanges may be in scope depending on the facts. We do not offer crypto tracing or recovery, and anyone promising to get crypto back should be treated with great suspicion.

In-scope claims should be assessed and reimbursed within five business days, with a limited ability to pause for further information. If yours has taken far longer, that is itself worth raising.

Almost certainly not. Fraudsters revisit previous victims, the FCA calls these recovery scams. We never make unsolicited contact. If we telephone you, it is because you asked us to.

See all frequently asked questions

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Next step

Check a claim for app fraud reimbursement, free.

Tell us what happened. We will tell you whether you have a claim, roughly what it is worth, and whether you would be better off going straight to your bank. That advice costs nothing and carries no obligation.

  • A senior consultant scopes the work, not a salesperson.
  • Fixed-price proposal within three working days.
  • We will tell you if you do not need the engagement you asked for.
  • Every engagement runs against signed authorisation and rules of engagement.
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