Authorised Push Payment (APP) scams – rules on reimbursement

We’re letting you know about new rules on Authorised Push Payment scams (APP scams) which apply to you, if your business is eligible for reimbursement in the event of a scam, from 7 October 2024.

Which types of businesses are eligible?

Eligible clients are micro-enterprises and small charities.

A micro-enterprise is one that employs fewer than ten people and has either an annual turnover or annual balance sheet total that does not exceed €2 million or sterling equivalent.

A small charity is a charity as defined by the Charities Act 2011, Charities and Trustee Investment (Scotland) Act 2005 or the Charities Act (Northern Ireland) 2008 with an annual income of less than £1 million per year.

What’s an APP scam?

An APP scam occurs when a scammer tricks you into making a payment to an account outside your control and the recipient isn’t the person you intended to pay, or the payment wasn’t for the purpose that you originally intended.

New APP scam reimbursement rules

On 7 October 2024, new rules came into effect for eligible clients who become the victim of an APP scam and request reimbursement. These new rules apply to UK sterling Faster Payments and CHAPS payments made on or after 7 October 2024.

If you make a claim, we’ll assess it on a case-by-case basis considering the evidence from you, the bank that received the payment and, where relevant, third parties such as the police. We’ll use any information we request from you to help us to progress your claim.

There’s a maximum limit for reimbursement of £85,000 per claim and we may deduct an excess of £100 from the reimbursement. In some cases, eligible clients may not be entitled to reimbursement under the new rules, and we explain circumstances where this may apply below.

When you make a claim, we’ll let you know the outcome as quickly as possible and if you’re entitled to reimbursement, we’ll aim to reimburse you no later than 35 days after you contact us.

We notified clients in August about upcoming changes to your Banking Terms and Conditions coming into effect on 1 November 2024, which include updated wording on the new rules.

Circumstances where you may not be entitled to reimbursement

You may not be entitled to reimbursement under the new rules if:

  • the payment was sent to another account that you control, whether with HSBC Innovation Banking or another bank;
  • the payment was sent to an account outside the UK;
  • you didn’t agree to the payment being sent (although you may still be entitled to a refund under different rules);
  • there’s a civil dispute between you and the person or business that received the payment;
  • you’ve been extremely careless when making the payment and ignored warnings from us and/or the police that the payment was likely to be a scam;
  • you didn’t promptly report the scam or suspected scam to us;
  • we haven’t received the information we need to assess your claim;
  • we reasonably suspect fraud on your part; or
  • it’s more than 13 months since you made the last APP scam payment.

The new rules also don’t apply to:

  • payments made before 7 October 2024;
  • payments made using your debit or credit cards, cheques or cash; international payments; or
  • payments sent to or received from credit unions, municipal banks and national savings banks.

These payments will still be investigated and you may still be reimbursed, so it’s important to report them.

How to tell us if you suspect you’ve been scammed

It’s very important you contact us as soon as you know or suspect that you’ve become a victim of an APP scam. You can call us using the details at the bottom of this page. We’ll ask you to contact the police if you haven’t already.

If you’re an eligible client, we’ll contact the bank that received your payment to try and recover the money. We’ll need to share your details with them, along with any other information you provide to us. We’ll let you know if we need any additional information and keep you up to date with the progress of your claim.

For more information on how to protect yourself from fraud, you can visit our Fraud Prevention Centre using the details at the end of this page.

Get in touch

If you ever find out or suspect you’ve become a victim of an APP scam:

If you have any questions, you can contact your Client Service team using the details below:

For more information on different types of frauds to be aware of, go to www.hsbcinnovationbanking.com then scroll to the bottom of the page and select ‘Fraud Prevention Centre’.