France: Consumer Protection & APP Fraud

Consumer Protection & APP Fraud

The Banque de France's Observatoire de la sécurité des moyens de paiement reported, at confirmed confidence, that payment fraud in France reached €618.4 million across 3.7 million transactions in H1 2025. Within that total, authorised-push-payment fraud rose 37% year-on-year and now represents 40% of total fraud value, making APP fraud the single largest and fastest-growing fraud category tracked in this reporting period. This is a confirmed, primary-source finding from France's own payment-security observatory and represents the most consequential consumer-protection signal in this cycle's evidence for France.

This fraud trajectory sits directly alongside the mandatory activation of Verification of Payee for SEPA Instant credit transfers from 9 October 2025, a control specifically designed to reduce account-mismatch-driven APP fraud by verifying payee identity before transfer completion. The consumer-protection significance of the juxtaposition is that APP fraud continued rising sharply across a reporting window that included VoP's mandatory activation, suggesting either that VoP's protective benefit had not yet fully materialised across transaction volume during the H1 2025 window, or that a meaningful share of APP fraud growth reflects social-engineering and authorisation-manipulation typologies that a payee-verification control alone does not directly counter.

No further consumer-redress mechanism, complaint-handling statistic, or liability-allocation rule specific to APP fraud victims in France was identified in this cycle's evidence. The finding here is limited to the fraud-volume and typology-growth data itself.

Outlook

The consumer-protection question to track into subsequent cycles is whether H2 2025 and 2026 fraud data, once reported by the Observatoire, shows APP fraud growth decelerating as VoP's protective effect matures, or whether fraud typologies continue outpacing the control. The planned extension of VoP to standard SEPA rails ahead of a pre-2027 deadline is directly relevant to this trajectory and should be watched as a consumer-protection-relevant infrastructure development.

Consumer Protection & APP Fraud

The Payment Services Regulation introduces a cascading-liability mechanism that involves the whole payments value chain in fraud prevention, moving beyond a model that places the primary reimbursement burden on the sending PSP alone. Payment service providers will be required to offer spending limits and blocking measures to customers, giving consumers direct tools to constrain their own exposure, while the PSR's reimbursement requirement is extended to cover employee-impersonation fraud specifically, a scenario not consistently captured under the current authorised-push-payment reimbursement frameworks. This is assessed at Probable confidence pending final legislative text following the 27 November 2025 political agreement.

The policy justification for this reform is directly empirical: Banque de France's Observatoire reported a 37% year-on-year rise in authorised-push-payment fraud, now 40% of total fraud value, out of €618.4 million in total payment fraud across 3.7 million transactions in H1 2025. Read together, the French fraud data and the PSR's cascading-liability design indicate that France functions as a bellwether case demonstrating the reform's necessity, rather than a jurisdiction where the reform is a lesser priority.

Outlook

The key marker to watch is the final PSR legislative text confirming the precise scope of the cascading-liability mechanism and the employee-impersonation reimbursement extension, expected alongside formal Official Journal publication in H1 2026.