The Payments Association (“TPA”) welcomes the opportunity to respond to the Home Office’s
call for evidence on unauthorised fraud in the UK, published on 15 July 2026 and closing on
7 October 2026. Unauthorised fraud, where payments are made from a victim’s account or
card without their knowledge or consent, is the largest category of fraud loss in the UK. It
touches every part of our membership, from banks and card issuers to acquirers, e-money
and payment institutions, wallet providers and the technology and fraud prevention firms that
support them.
This response reflects views and evidence from TPA members gathered at a members’
evidence session held on 28 September 2026 and through follow-up written submissions,
including from an app-based business banking provider, a member that operates a consumer
scam-checking service, an e-money institution that provides accounts and payment rails to
other financial institutions and a financial crime consultancy drawing on its clients’ experience.
Contributors included banks and building societies, app-based payment firms, fraud
prevention specialists and advisers. TPA’s membership holds a diverse range of views, and
this response cannot and does not claim to represent the position of every member on every
question. Where members’ practice or views differ, we say so.
We are grateful to the contributors to this response, which has been drafted by Robert
Courtneidge on behalf of TPA’s Policy team. We note that the Home Office will share
responses with HM Treasury. We welcome that, because the questions raised here about
authorisation, authentication and liability bear directly on HM Treasury’s current reform of the
Payment Services Regulations 2017 (“PSRs”) and on the move of strong customer
authentication requirements into FCA rules. We cross-refer to our response to HM Treasury’s
Modernising Payment Services Regulation consultation where relevant.
We answer the call for evidence’s 27 questions below, in order and in the Home Office’s own
wording, grouped under its seven sections. Where our members do not hold specific evidence
on a question, we say so rather than speculate.
The Payments Association is content for the Home Office and HM Treasury to identify it by
name as a respondent to this call for evidence.
