DISP 2.7.7 guidance updated on APP fraud and pension beneficiary complaints

The Financial Conduct Authority published updated guidance in its Handbook on 28 November 2025 clarifying the scope of complaints the Financial Ombudsman Service can consider. The guidance, DISP 2.7.7, dated 28/11/2025, states that DISP 2.7.6R(2B) includes complaints that a respondent did not do enough to prevent or respond to an alleged authorised push payment fraud¹.

DISP 2.7.6 is a rule dated 30/11/2024, and DISP 2.7.7 is guidance sitting alongside it¹. The chapter, DISP 2, sets out the scope of the Ombudsman's two jurisdictions: the Compulsory Jurisdiction and the Voluntary Jurisdiction¹. The Compulsory Jurisdiction is not restricted to regulated activities, payment services, the issuance of electronic money and CBTL business, and covers certain complaints against firms, including businesses that were firms at the time of the events complained about¹.

The guidance sits within DISP 2.7, which deals with whether a complainant is eligible. An eligible complainant must be a person that is a consumer or a micro-enterprise¹. The scope of the two jurisdictions depends on the type of activity, the place where the activity was carried on, whether the complainant is eligible, and whether the complaint was referred to the Financial Ombudsman Service in time¹.

The chapter also sets out other categories of complaint covered by the Compulsory Jurisdiction, including relevant credit-related complaints against businesses covered by a standard licence under the Consumer Credit Act 1974 at the time of the events complained about, and relevant transitional funeral plan complaints about events before 29 July 2022 referred to the Financial Ombudsman Service on or after that date¹. DISP App 5 contains complaint handling rules and guidance for relevant motor finance discretionary commission arrangement complaints and motor finance non-discretionary commission arrangement complaints¹.

The updated guidance does not itself set out a reimbursement entitlement or a maximum refund figure. The maximum refund for authorised push payment fraud and the wider reimbursement process are dealt with elsewhere and are not covered in the material published on 28 November 2025¹.

Why it matters for households

The change is about which complaints the Financial Ombudsman Service can take on, not about a new payment or refund. Someone who believes their bank or payment firm did not do enough to prevent or respond to an authorised push payment fraud now has the scope of that complaint confirmed in the Handbook guidance, dated 28 November 2025¹.

Eligibility still depends on the complainant being a consumer or a micro-enterprise, and on the complaint being referred in time¹. The guidance applies to complaints falling within DISP 2.7.6R(2B), the rule it clarifies¹.

For households dealing with an alleged push payment fraud, the practical effect is that the Ombudsman's jurisdiction over the firm's conduct, as distinct from the underlying transaction, is set out in the guidance. The scams and fraud pages cover how reimbursement works in practice, and the regulation and policy section covers the wider framework.

What happens next

The guidance took effect on 28 November 2025¹. The chapter page records that DISP 2 was last updated on 15/07/2026, with a future version dated 25/10/2027¹. No further steps connected to the 28 November 2025 guidance have been reported.