The £100 excess on bank transfer scam refunds

If a fraudster tricks you into sending money by bank transfer, the rules that came in on 7 October 2024 say your bank should refund you. But the refund is not always the full amount. Your bank can take up to £100 off what it pays back, and that deduction is known as the claim excess¹.

The excess is a choice, not an automatic charge. The rules let the sending bank apply the full £100, a lower amount, or nothing at all³. It must not be charged to a customer the bank considers vulnerable⁴. Some banks and building societies say in their own terms that they may apply it, which is why two people with identical losses can end up with different amounts back⁵.

The excess sits inside a much larger figure. The maximum you can claim under the rules is £85,000, and the £100 is simply the slice at the bottom that a bank may keep⁷. The regulator's own estimate is that the excess affects roughly 30% of cases by volume but less than 1% of the total value of APP fraud³.

Up to £100 can be taken off a scam refund

The claim excess is the amount a bank may keep back when it reimburses an authorised push payment scam. The regulator's policy statement confirms a £100 excess, and the rules describe it as up to £100 for each scam claim¹. Banks put the same wording in their own documents: one says it may apply an excess of up to £100 to a claim under the scheme, and another states plainly that a £100 excess may apply⁵.

The important word is "may". The policy statement is explicit that the sending payment firm can decide whether to apply a full excess of £100, a lower excess, or no excess at all to a reimbursable claim³. That discretion is why the deduction is not something a customer can predict from the rules alone. It depends on the firm.

There is also a second route by which an excess can appear. Under the Faster Payments reimbursement rules, a receiving payment firm may choose to deduct 50% of the maximum claim excess value where the sending firm chooses not to levy the excess or levies a lower one⁴. In plain terms, the deduction can in some cases come from the bank that received the money rather than the one that sent it.

For a consumer, the practical effect is that the headline figure you are told you will get back may be £100 less than the amount you lost, and the reason will be a rule rather than a judgment about your case. If the bank does apply it, the deduction is taken from the refund, not billed separately.

Who does not pay the excess: vulnerable customers

The rules single out one group who must not lose the £100: vulnerable customers. The policy statement confirms that the excess may not be charged to vulnerable consumers³. Independent guidance puts it the same way, that a bank can deduct £100 from the refund unless the customer is considered vulnerable under the rules².

The definition of vulnerability is broad and is set out by the Financial Conduct Authority, and a customer deemed vulnerable to the specific type of scam they fell for is not subject to the gross negligence test or the claim excess⁹. That second point matters: it is not a general test of whether someone is a vulnerable person, but whether they were vulnerable to that particular scam.

Where the bank has to decide, it looks at your personal circumstances, including the circumstances in which the fraud took place and your ability to protect yourself while making the payment¹¹. The regulator also required firms to provide additional protections for vulnerable customers as part of the reimbursement regime¹².

If you think the excess has been applied to you unfairly because of your circumstances, that is a point you can raise in a complaint. The extra refund protection if you are vulnerable page sets out how vulnerability is assessed, and the consumer standard of caution page explains the separate test a bank uses when it considers refusing a refund for gross negligence.

How the excess fits within the £85,000 reimbursement limit

The £100 excess and the £85,000 cap are two ends of the same calculation. The rules require banks and other payment service providers to reimburse you up to a maximum of £85,000 if you are the victim of an APP scam⁸. Independent guidance states the same maximum, and the regulator's own dashboard refers to the £100 excess and the £85,000 cap as the two boundaries of a claim¹.

In practice the arithmetic runs like this. If you lost £80 and the bank applies the full excess, the deduction wipes out the claim entirely, because the excess is capped at £100 and cannot take a refund below zero. On a larger loss, the cap limits the claim to £85,000 before the excess is considered.

The cap is a maximum per victim, and the excess is a maximum per claim, so neither figure scales with the number of payments you made. The regulator's dashboard tracks the value of APP scam losses that fall below the £100 excess and above the £85,000 cap separately, which is how the two boundaries are monitored¹.

Which payments and claims the refund rules cover

The reimbursement requirement was introduced within Faster Payments, and the regulator has since set out requirements for APP fraud committed over the CHAPS payment system as well¹⁴. Independent guidance lists both Faster Payments and CHAPS as covered¹⁶. So the excess can arise on a CHAPS payment in the same way as on a Faster Payments transfer.

The rules require payment firms to reimburse all in-scope customers who fall victim to APP fraud in most cases¹². There are exceptions. A consumer who is themselves party to the fraud or dishonesty giving rise to their claim, including first-party fraud, is not eligible for reimbursement⁴. The scheme rules state that the victim must not be party to the fraud¹⁰. Independent reporting at the time the rules were made confirmed that firms would not reimburse customers who acted fraudulently or with gross negligence¹⁷.

Banks also list the claims they will not pay. These include payments where you have made a false claim, and claims you have misrepresented or falsified¹⁸. Those are different from the excess: they remove the refund rather than reduce it.

One further point of confusion is the claim ceiling some banks quote. Several firms describe a maximum claim amount of £120,000, applying to any related payments considered part of the same scam, and one states that the amount you claim must be under £120,000²⁰. That figure sits alongside the £85,000 maximum reimbursement in the rules, and the two are not the same thing. Where a bank's own terms and the regulator's rules appear to give different ceilings, the rules set the reimbursement maximum.

How much the excess affects: about 30% of cases, under 1% of the money

The regulator's own assessment, published in December 2023, is that while the excess impacts approximately 30% of cases by volume, it represents less than 1% of the total value of APP fraud cases³. That is the clearest picture of who actually feels it: a large share of claims, but a very small share of the money lost.

The reason is arithmetic. A £100 deduction is significant on a small loss and negligible on a large one. Because most APP scam cases are for relatively modest sums, the excess bites on a large number of them while barely touching the total value.

The wider effect of the reimbursement rules has been to raise the share of cases that get paid. Since the law was changed, the reimbursement rate has increased from around 54% to 65%²². Before the rules took effect, the picture varied sharply between firms: one building society's figures for cases closed in 2024, before 7 October 2024, show it fully reimbursed 97% and partially reimbursed 2% of reported APP scam cases¹³.

Making a claim and what happens next

A claim starts with your bank, and the clock is short. Most APP fraud victims should be reimbursed within five business days, unless the bank or payment provider needs to gather more information about what happened⁹. Claims are also subject to a 13-month time limit after the last payment was sent to the scammer as part of the same scam⁹.

The steps are straightforward, and the claiming a refund from your bank after a push payment loss page walks through them in detail:

1. Report the scam to your bank as soon as you realise what has happened, and to the police.
2. Give the bank the details of the payments, the recipient and how the scam worked.
3. Answer the bank's questions about your circumstances, which is also where vulnerability is assessed.
4. Wait for the decision. If the bank applies an excess, ask which rule it is relying on and whether it has considered vulnerability.
5. If the refund is refused or reduced and you disagree, complain to the bank first, then take the case to the Financial Ombudsman Service.

The ombudsman's guidance is clear that it can look at cases where you were tricked into making a payment, and that it will consider whether the rules apply and whether you were particularly vulnerable to the specific type of APP scam, in which case the bank or payment service provider must reimburse you⁸. That is the backstop if a bank refuses.

If a refund is refused altogether, the how to complain to your bank about a scam refund and taking a refused scam refund to the Financial Ombudsman pages set out the process. Free, impartial help is available from MoneyHelper and from debt advice charities if a scam has left you struggling, and the where to report a scam in England, Wales, Scotland and Northern Ireland page covers reporting in each nation.