How fraud, risk and compliance teams can prepare for five-day reimbursement

The UK has proven it: payment service providers (PSPs) can resolve fraud claims in five days or fewer. For EU institutions awaiting PSD3 and the new Payment Services Regulation (PSR), the question is no longer whether it’s possible—it’s how quickly they can adapt. What’s at stake isn’t just compliance. It’s customer trust, operational credibility, and competitive resilience.

Why the five-day target matters

Since October 2024, UK PSPs have been required to reimburse victims of Authorised Push Payment (APP) scams within five business days. Six months in, major banks report that over 90% of claims meet that threshold.

This speed is not a nice-to-have. In today’s real-time payment landscape, delays increase losses, degrade customer experience, and amplify reputational risk. The five-day benchmark is emerging as a de facto expectation—not just in the UK, but across all jurisdictions preparing to tighten reimbursement requirements.

EU regulation may use different phrasing—"without undue delay" instead of a fixed deadline—but the implicit pressure is clear: institutions unable to respond fast will be viewed as non-compliant, ineffective, or both.

What makes fast resolution possible?

Rapid reimbursement isn't the result of more headcount. It's the product of infrastructure built for speed, coordination, and automation. Leading UK banks have adopted a combination of:

• Real-time fraud signal ingestion

• Automated case triage and routing

• Collaborative alert enrichment across PSPs

• Integrated workflows between fraud, risk, and customer operations

This transformation reflects a fundamental shift: fraud response is no longer a back-office function. It is now an orchestrated, front-line capability that must operate across internal systems and external institutions—with minimal latency.

Why most institutions aren’t ready

Many EU PSPs still operate with fragmented fraud operations. Detection systems sit on one stack, case management on another. Investigations rely on manual escalations and email threads. Cross-institutional intelligence is patchy at best—and often blocked by privacy concerns or incompatible systems.

Under PSD3, this architecture simply won’t scale.

Institutions that want to meet five-day expectations will need to unify decision-making, automate low-risk flows, and enable real-time collaboration without centralising data. And that’s not just a technical challenge—it’s a governance one.

Getting ahead with secure collaboration

This is where forward-looking PSPs are already investing. Instead of waiting for formal mandates, they are deploying secure data collaboration capabilities to shorten time-to-resolution. That includes:

• Collaborating on beneficiary risk scoring without exposing personal data

• Using encrypted fraud signals from peer institutions to enrich case files

• Escalating alerts across the ecosystem while preserving compliance boundaries

These capabilities depend on privacy-preserving computation, zero-trust frameworks, and policy-enforced data governance—features central to the secure data collaboration model adopted by institutions looking to lead, not follow.

The benefit is twofold: faster resolution, and smarter prevention. Real-time collaboration doesn't just close cases faster—it stops more fraud from happening in the first place.

The cost of standing still

As UK institutions accelerate, the pressure on EU PSPs is growing. Payment regulators, customers, and even commercial partners are watching closely.

In an environment where liability is shifting, trust is fragile, and fraud is evolving, the ability to act quickly becomes a differentiator. Institutions that meet reimbursement timelines will gain reputational strength and operational flexibility. Those that fall behind may find themselves under scrutiny—not only from supervisors, but from a customer base that now expects a rapid, coordinated response.

What to do now

For fraud, risk, and compliance leaders, now is the time to ask hard questions:

• Can we trace and resolve high-risk claims within five days—at scale?

• Are we equipped to detect cross-institutional risk without violating privacy?

• Do we have the infrastructure to move from bilateral coordination to ecosystem-level collaboration?

If the answer to any of these is no, the path forward is clear: invest in operational readiness today. The transition to faster, fairer reimbursement is not coming, it’s already here.