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title: Netherlands — Consumer Protection & APP Fraud | World Payments Monitor
canonical: https://payments.gi/jurisdictions/netherlands/w10/
publisher: Asymmetric Intelligence

### W10 Consumer Protection & APP Fraud Probable confirmed 2026-06-27

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.

Standing sub-brief · as of 27 June 2026 173 words · last cycle 2026-06-27

#### Consumer Protection & APP Fraud

Consumer protection rests on PSD2/Wft conduct rules supervised by the AFM, with Kifid as the recognised out-of-court ombudsman for consumers and small businesses. The key divergence from the UK is structural: there is no statutory APP-fraud mandatory-reimbursement scheme equivalent to the UK PSR regime. Reimbursement is driven by bank goodwill policies and Kifid case law. The bank-PSP focus is relevant here, since liability sits with banks under goodwill and case-law frameworks rather than a statutory mandate.

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)**

1. T2 [https://www.kifid.nl/about-kifid/](https://www.kifid.nl/about-kifid/) retrieved 2026-06-27
2. T3 [https://nltimes.nl/2026/04/23/new-ruling-makes-compensation-easier-victims-bank-impersonation-fraud](https://nltimes.nl/2026/04/23/new-ruling-makes-compensation-easier-victims-bank-impersonation-fraud) retrieved 2026-06-27
3. T3 [https://www.eur.nl/en/esl/news/forthcoming-european-regulation-who-bears-liability-cases-online-payment-fraud](https://www.eur.nl/en/esl/news/forthcoming-european-regulation-who-bears-liability-cases-online-payment-fraud) retrieved 2026-06-27
4. T1 [https://www.afm.nl/en/consumenten/klachten](https://www.afm.nl/en/consumenten/klachten) retrieved 2026-06-27
