title: Ireland — Consumer Protection & APP Fraud | World Payments Monitor canonical: https://payments.gi/jurisdictions/ireland/w10/ publisher: Asymmetric Intelligence ### W10 Consumer Protection & APP Fraud limited signal Probable confirmed 2026-06-24 Consumer protection is governed by the Consumer Protection Code 2025 (effective March 2026) and supervised by the CBI's Consumer Protection Directorate; the Financial Services and Pensions Ombudsman (FSPO) is the dispute-resolution route. Unlike the UK (PSR mandatory APP reimbursement from 7 October 2024), Ireland has NO mandatory APP-fraud reimbursement scheme; APP losses (~EUR 9.9m in 2022) are addressed via CBI Consumer Protection Outlook expectations and a whole-of-system National Payments Strategy approach (a legislated shared fraud database to be developed by BPFI, plus cross-sectoral cooperation). An Oireachtas Finance Committee report (October 2024) recommended a shared fraud database and greater coordination. Standing sub-brief · as of 26 June 2026 249 words · last cycle 2026-09-28 #### Consumer Protection & APP Fraud Ireland's approach to authorised push payment fraud diverges sharply from the UK. Ireland has no mandatory reimbursement scheme, unlike the UK, where the PSR introduced mandatory APP reimbursement from 7 October 2024; APP losses of around EUR 9.9m in 2022 are addressed via CBI Consumer Protection Outlook expectations and a whole-of-system National Payments Strategy approach, with a legislated shared fraud database to be developed by BPFI and the Department of Justice to legislate, and cross-sectoral cooperation extended to online platforms, telcos and their regulators. The absence of a mandatory reimbursement obligation materially differentiates Ireland's consumer-protection liability exposure from the UK's, affecting both bank and non-bank PSPs that hold consumer accounts. Rather than imposing a reimbursement liability on PSPs, Ireland's model leans on system-wide coordination and a shared fraud database, drawing in non-financial actors such as platforms and telecommunications providers. This is a structurally lighter cardholder-recourse posture than the UK PSR regime, placing the emphasis on prevention and cross-sectoral data-sharing rather than on a backstop reimbursement guarantee. #### Outlook The consumer-protection and APP-fraud trajectory is escalating in policy activity even without a mandatory reimbursement scheme. The legislated BPFI-developed shared fraud database and the whole-of-system National Payments Strategy approach are the principal developments to watch, alongside the cross-sectoral extension to platforms and telcos. Ireland's continued divergence from the UK mandatory-reimbursement model is itself a standing feature that materially shapes liability exposure for Irish PSPs, and the Consumer Protection Code 2025's anti-fraud requirements (W1b) reinforce the prevention-led posture. Periodic update · new data 2026-09-28 #### Consumer Protection & APP Fraud Payment institutions and e-money institutions authorised in Ireland are now subject to the Consumer Protection Code 2025, given effect through the Section 48 Regulations 2025 and the Standards for Business Regulations 2025 — a conduct framework that applies directly to this sector's authorised firms. Separately, the Central Bank's Consumer Protection Outlook Report sets out an expectation that firms maintain effective fraud-mitigation measures and support victims of authorised push payment scams in recovering funds. This conduct expectation is notable for what it is not: it is a supervisory expectation set out in an outlook report, not a mandatory reimbursement obligation with a defined legal liability allocation. That distinguishes Ireland's current position from the UK's live Payment Systems Regulator reimbursement regime, and situates Ireland instead alongside the EU's PSR3/PSD3 mandatory-reimbursement framework, which remains in the EU legislative process rather than in force. Firms authorised in Ireland today therefore face a conduct expectation to act on APP fraud without yet facing a codified mandatory-reimbursement liability rule of the kind already operative in the UK. #### Outlook The clearest development to watch is the progress of the EU's PSR3/PSD3 legislative process: its eventual adoption and transposition would convert the CBI's current conduct expectation into a codified mandatory-reimbursement obligation, materially changing the liability allocation for APP fraud losses among PI/EMI firms authorised in Ireland. Until then, firms operate under the Consumer Protection Code 2025 and the Outlook Report's conduct expectations rather than a binding reimbursement rule. **1 earlier distinct update(s)** Periodic update · new data 2026-09-14 #### Consumer Protection & APP Fraud Fraudulent payments in Ireland reached EUR 57 million in 2024, driven largely by AI-enabled social engineering, according to supervisory commentary referencing Central Bank of Ireland data. This is a Probable-confidence, dated dashboard-tier finding that quantifies the scale of authorised-push-payment-style fraud exposure in the Irish market as of the most recent full year for which data was available. Against this fraud backdrop, IBAN-name checking has been mandatory for SEPA Instant transfers since 9 October 2025, functioning as a Confirmation-of-Payee-style verification requirement across the SEPA Instant scheme generally, not an Ireland-specific rule but one directly applicable to Irish payment flows. Separately, the CBI published its Consumer Protection Code 2025, including Standards for Business regulations issued under the Central Bank Reform Act 2010 section 17A, updating the standards-for-business obligations applicable to payment firms operating in Ireland. Once transposed, PSD3/PSR is also expected to expand authorised-push-payment fraud liability provisions, adding a further forward-looking layer to Ireland's consumer-protection-and-fraud landscape beyond the currently in-force IBAN-name-check and Consumer Protection Code measures. #### Outlook Watch for updated fraud-loss figures beyond the 2024 EUR 57 million baseline as AI-enabled social-engineering techniques continue to evolve, and for the practical detail of PSD3/PSR's expanded APP-fraud liability provisions once transposition proceeds. **Sources and findings (4)** 1. T3 [https://kpmg.com/ie/en/insights/consulting/authorised-push-payment-scams-consulting.html](https://kpmg.com/ie/en/insights/consulting/authorised-push-payment-scams-consulting.html) retrieved 2026-06-24 2. T1 [https://www.oireachtas.ie/en/press-centre/press-releases/20241023-committee-on-finance-public-expenditure-and-reform-and-taoiseach-publishes-report-on-authorised-push-payment-fraud-recommends-shared-fraud-database-greater-coordination-and-communication-by-stakeholders/](https://www.oireachtas.ie/en/press-centre/press-releases/20241023-committee-on-finance-public-expenditure-and-reform-and-taoiseach-publishes-report-on-authorised-push-payment-fraud-recommends-shared-fraud-database-greater-coordination-and-communication-by-stakeholders/) retrieved 2026-06-24 3. T2 [https://bpfi.ie/bpfi-opening-statement-to-oireachtas-finance-committee-3rd-december-2025/](https://bpfi.ie/bpfi-opening-statement-to-oireachtas-finance-committee-3rd-december-2025/) retrieved 2026-06-24 4. T3 [https://www.williamfry.com/knowledge/national-payments-strategy-launched-by-the-minister-for-finance/](https://www.williamfry.com/knowledge/national-payments-strategy-launched-by-the-minister-for-finance/) retrieved 2026-06-24