Most APP fraud begins on digital platforms, yet liability sits with payment providers. This TPA paper explores how accountability must evolve.
Authorised push payment (APP) fraud is one of the most significant threats facing consumers and businesses today. While regulatory reforms have strengthened protections at the point of payment, the majority of scams now begin earlier, on digital platforms, marketplaces, and messaging services.
This white paper by The Payments Association examines how fraud develops in practice, from initial exposure through to financial loss, and explores whether current accountability frameworks reflect that reality.
What the paper covers
- Where and how APP fraud begins, including the growing role of digital platforms
- The multi-stage journey from scam exposure to financial loss
- The structural imbalance between platform activity and financial liability
- The economic incentives that allow scam advertising to persist
- Emerging UK and international regulatory developments
- A proposed framework for shared accountability across the fraud chain
Why this matters
As scam exposure increasingly occurs within platform-controlled environments, effective fraud prevention requires a broader, system-wide response.
This paper argues that responsibility should align with where prevention is possible. Where organisations operate systems that facilitate large-scale scam exposure, they should play a proportionate role in mitigating those risks.
What it calls for
- Enforceable standards for scam prevention on digital platforms
- Stronger advertiser verification and repeat-offender controls
- Faster removal of fraudulent content
- Mandatory cross-sector intelligence sharing
- Greater transparency and regulatory oversight
