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Consumer protection rests on PSD2/Wft conduct rules supervised by AFM, with Kifid (the Dutch Institute for Financial Disputes) as the recognised out-of-court complaints/ombudsman route for consumers and small businesses. There is no statutory APP-fraud mandatory-reimbursement scheme equivalent to the UK PSR regime; reimbursement for spoofing/helpdesk fraud has been driven by bank goodwill policies and Kifid case law. An April 2026 Kifid Appeals Committee ruling tightened standards so 'gross negligence' rarely applies in bank-helpdesk fraud, easing reimbursement, while a notable case denied compensation where the fraudster impersonated DNB rather than the bank. The forthcoming EU PSR is set to reshape online-fraud liability.
An April 2026 Kifid Appeals Committee ruling tightened 'gross negligence' standards so the standard rarely applies in bank-helpdesk fraud, easing reimbursement; a notable case denied compensation where the fraudster impersonated DNB rather than the bank. The forthcoming EU PSR is set to reshape online-fraud liability.
Outlook
W10 is established but held at Assessed. The absence of statutory APP reimbursement means Dutch liability is goodwill and case-law driven — a material divergence operators must factor versus the UK. The forward watch is the EU PSR, which is expected to address online-fraud liability allocation.
no periodic updates on record for this sub-brief
Sources and findings (4)
- T2https://www.kifid.nl/about-kifid/retrieved
- T3https://nltimes.nl/2026/04/23/new-ruling-makes-compensation-easier-victims-bank-impersonation-fraudretrieved
- T3https://www.eur.nl/en/esl/news/forthcoming-european-regulation-who-bears-liability-cases-online-payment-fraudretrieved
- T1https://www.afm.nl/en/consumenten/klachtenretrieved