Get in Touch
T: +44 20 3695 9251
E: info@grtconsult.com
71-75 Shelton Street Covent Garden, London, WC2H 9JQ
Get in Touch
T: +44 20 3695 9251
E: info@grtconsult.com
71-75 Shelton Street Covent Garden, London, WC2H 9JQ
Pay.UK dated FPS Reimbursement Rules – Schedule 4 Version 4.0 on 01 May 2026. The schedule applies to all Directed PSPs that participate in Faster Payments and provide Relevant accounts — banks, building societies and EMIs in scope of PSR Specific Direction 20 — whether or not they are FPS Members. The reimbursement requirement itself has applied to reimbursable FPS APP scam payments executed from 7 October 2024; later PSR pages record an independent review (news dated 01/07/2026) and a dashboard update of 30 July 2026 for Q1 2026.
Schedule 4 is the Faster Payments Operator’s rulebook for the reimbursement requirement. Sending PSPs still reimburse in-scope victims; receiving PSPs still pay the Reimbursable Contribution Amount; Pay.UK still monitors. Version 4.0 does not move the 7 October 2024 implementation date. It changes how you read an in-scope payment, how you label the reimbursability assessment, how you treat victim-beneficiary cases, and how you may pay the contribution other than via FPS.
The PDF URL path contains /2024/12/; lock the cover date (01 May 2026), not the path.
Operational consequences:
A later independent review and a later dashboard update exist on PSR pages. Those pages do not agree on whether Frontier published in Q1, in Q2, or on 1 July. Flag the conflict. Do not “fix” it in MI commentary.
| Business type / role | Core obligations under v4.0 | Clock that still binds | Official references |
|---|---|---|---|
| Sending PSP | Reimburse reimbursable APP scam payments (excess, cap, standard of caution, 13-month window). Notify the receiving PSP within two business hours. Assess after the three-business-day opportunity to respond. Pay by close of day 5 unless stop-the-clock applies. Close by day 35 | 7 October 2024 implementation date (unchanged) | Schedule 4 v4.0 rules 3.1–3.12, 4.1–4.15; PS25/5 |
| Receiving PSP | Pay the Reimbursable Contribution Amount (half the Reimbursable Amount, apportioned by value received) within five business days. Repatriate recovered funds on the rule 6 split. Update RCMS | Five business days for the contribution; three business days for repatriation after internal approvals | Rules 5.1–5.8, 6.1–6.5 |
| Indirect / sponsored Directed PSP | Accountable to Pay.UK for Schedule 4. A sponsoring DCS bank is not responsible unless it controls access to the claim funds | Same clocks as a Member | §§2.5 and 3 |
| Pay.UK (FPS operator) | Monitor Directed PSPs under SD19; RCMS Core is the expected Standard A channel | Effective Date still 7 October 2024 | §7 |
| Credit unions, municipal banks, national savings banks | Relevant-account definition continues to exclude these account types | Out of Schedule 4 for those accounts | §10 definition of Relevant account |
Operational tip: Rule 3.10.4 now tests whether the payment is received in a Relevant account, not “settled”. If your claims script still says “settled”, you will accept or reject on the wrong fact.
| Step | Action | What operational staff must deliver | Official reference |
|---|---|---|---|
| 1 | Replace the rulebook copy | Controlled copy of Schedule 4 v4.0 dated 01 May 2026. Retire v3.5 (04/12/2024) from RCMS desk instructions | PDF cover and §1.1 |
| 2 | Patch the in-scope test | Five-limb FPS APP scam payment test. Limb 4: payment is received in a Relevant account under the control of a receiving PSP in the UK that is not controlled by the Consumer | Rule 3.10, including 3.10.4 |
| 3 | Split “APP scam payment” from “reimbursable” | New rule 3.11 heading for the six-limb assessment (standard of caution / vulnerability; not party to the fraud; not a dishonest claim; not a private civil dispute; not an unlawful purpose; reported within 13 months and not before 7 October 2024) | Rules 3.10 and 3.11 |
| 4 | Add victim-beneficiary to the playbook | New definition: one victim pays a further victim, who then pays a criminal. Footnotes on 4.11.1 and 5.5: POCA 2002 and the MLRs may restrict the Reimbursable Amount and the contribution | §10; footnotes to 4.11.1 and 5.5 |
| 5 | Exception path for the contribution | Default remains FPS. Rule 5.8 allows another method by exception if receiving and sending PSP(s) agree in writing | Rule 5.8 |
| 6 | Re-confirm clocks already live | Two business hours to notify; three business days to respond; five business days to reimburse (stop-the-clock only for rule 4.6 reasons); close by day 35; contribution in five business days | Rules 4.1–4.9, 4.14, 5.7 |
| 7 | Later PSR pages — record, do not reconcile | Diary PSR news dated 01/07/2026 (Frontier) and the dashboard “Updated: 30 July 2026” for Q1 2026. Official pages disagree on Q1 vs Q2 vs 1 July. Quote each page | PSR 1 July 2026 news; Q1 2026 dashboard; One year on |
A free self-assessment against the live PSR requirement: PSR APP Scams Reimbursement Diagnostic.
/2024/12/ or the cover “©Pay.UK 2025” line as the effective date.GRT Consulting supports operational teams with:
Start with the PSR APP Scams Reimbursement Diagnostic, then contact us: T: +44 20 3695 9251 E: info@grtconsult.com Web: grtconsult.com
Sources
