If a fraudster talks you into sending a bank transfer and you lose more than £85,000, the mandatory reimbursement scheme will not cover the whole amount. The scheme caps a claim at £85,000, and claims may be subject to a £100 excess, except where victims are found to be vulnerable1. That cap is a limit on the scheme, not on your rights: you can still complain to your bank, and if you are unhappy with its answer you can take the case to the Financial Ombudsman Service, whose award limit is higher than the scheme cap3.
If a fraudster talks you into sending a bank transfer and you lose more than £85,000, the mandatory reimbursement scheme will not cover the whole amount. The scheme caps a claim at £85,000, and claims may be subject to a £100 excess, except where victims are found to be vulnerable1. That cap is a limit on the scheme, not on your rights: you can still complain to your bank, and if you are unhappy with its answer you can take the case to the Financial Ombudsman Service, whose award limit is higher than the scheme cap3.
The gap matters because authorised push payment (APP) fraud is large and growing. UK Finance recorded a 19 per cent increase in losses, to £576.4 million, in 20255. Purchase scams accounted for £118.1m of that, and advance fee scams £58.4m, both the highest ever recorded5. APP scams are the second biggest type of payment fraud reported by UK Finance6.
This page sets out what happens above the £85,000 line: how the ombudsman's higher award limit works, the eight-week rule for complaining to your bank first, how the ombudsman decides a case, what it can order, and where its limit stops and the courts begin.
Losses above £85,000: the ombudsman's award limit is higher than the scheme cap
The mandatory reimbursement scheme and the ombudsman are two different things, and the difference is what matters above £85,000. The scheme is a rulebook obligation on payment firms: it requires them to reimburse all in-scope customers who fall victim to APP fraud in most cases, up to a maximum of £85,00011. The ombudsman is a dispute resolution service that can look at how a firm handled your claim and order compensation on a different scale.
The ombudsman's award limit is £455,000 for complaints referred on or after 1 April 2026 about acts or omissions on or after 1 April 201912. Earlier limits apply to complaints referred before that date: £350,000 for complaints about issues after 1 April 2019, rising in line with inflation each year7, and another source gives £445,0004. The limit has moved over time, so the figure that applies depends on when the complaint was referred.
The ombudsman can help victims of high-value scams with losses above £85,000 escalate their complaint3. It deals with complaints about financial businesses that provide services or products in the UK, and can usually help individual or joint consumers regardless of nationality or where they live13.
What the ombudsman cannot do is order a firm to pay more than its award limit. If your loss exceeds the limit that applies to your complaint, the ombudsman can order up to that limit and no further. The rest is a matter for the courts, which is covered below.
Complain to your bank first: the eight-week rule
The ombudsman will not take a case until you have complained to the firm.
That eight-week clock is the practical deadline to watch. If your bank has not resolved the claim within eight weeks, you do not have to wait any longer before going to the ombudsman. If it has responded and you disagree, you can refer the complaint.
There is a separate deadline on the claim itself. You must submit your reimbursement claim within 13 months of the final fraudulent payment10. Claims are subject to that 13-month time limit after the last payment was sent to the scammer as part of the same scam9. Miss it and the scheme route closes.
On the deadline for referring a complaint to the ombudsman once you have a final response, the sources give different points. One says within six months of receiving your outcome letter; another says within six months of the date of the final response letter, or eight weeks after the complaint was received14. Both give six months, but they measure it from different points. Check the deadline printed in your own final response letter and treat the earlier date as the one that matters.
Taking your case to the Financial Ombudsman Service
The ombudsman's remit covers APP fraud complaints specifically. The FCA's dispute resolution rules include any complaint that the respondent did not do enough to prevent, or respond to, an alleged authorised push payment fraud16. That is the hook: the complaint is not only about whether the scheme cap applies, but about whether the firm did enough.
The regulator confirmed the route when it made the reimbursement rules. If a consumer is unhappy with how their payment firm has assessed their APP scam claim under the policy, they can take their complaint to the Financial Ombudsman Service17. The ombudsman has also said it will take the industry code that preceded the mandatory scheme into account as a relevant consideration when determining new consumer complaints about APP scams18.
The scale of the problem is worth knowing when you weigh up whether to pursue it. In 2024 alone there were around 185,000 APP fraud cases a year involving UK individuals and businesses19. Losses in the first half of 2021 alone totalled £355 million, which the regulator described as likely to be an underestimate20. By payment channel in 2025, internet banking accounted for £218.5m of APP fraud losses, branch payments £35.8m and telephone banking £20.3m5.
To start, you fill in the ombudsman's complaint form. If you are considering using AI to help you complete the form, the ombudsman asks you to read its guidelines on using AI before you start8.
How the ombudsman decides and what it can order
The ombudsman decides complaints on what is fair and reasonable in the circumstances of the case, taking the relevant rules and codes into account. For APP scams, that means the reimbursement rules and, where they bear on the case, the earlier industry code18.
What it can order is compensation, up to its award limit. The limit is £350,000 for complaints about issues after 1 April 2019, rising in line with inflation each year7. That is the ceiling on what the ombudsman can require a firm to pay for a single complaint, and it is the reason a loss above £85,000 is not necessarily a loss above the award limit.
The scheme's own cap is separate and lower. The maximum amount that can be claimed for an APP fraud from 7 October 2024 is £85,00021. The rules require payment firms to reimburse all in-scope customers who fall victim to APP fraud in most cases, but within that cap11. The £100 excess is a deduction, not a cap: firms can choose to apply a £100 claims excess, except where victims are found to be vulnerable22. By volume the excess impacts approximately 30 per cent of cases, though it represents less than 1 per cent of the total value of APP fraud cases17.
So there are three numbers to keep apart. The scheme reimburses up to £85,000, less a possible £100 excess1. The ombudsman's award limit is £350,000 for complaints about issues after 1 April 2019, rising in line with inflation each year7. And the underlying loss can be larger than either.
Compensation, interest and tax on what you get back
The scheme has been paying out at a high rate since it began. Between 7 October 2024 and 31 March 2026, 88% (£316m) of the money lost to APP scams was reimbursed to victims2. In the first three months of the mandatory scheme, 86% of money lost to APP scams, totalling around £27m, was returned to victims23.
That is a marked change. In 2022, only 59% of APP fraud losses were returned to victims, either as direct refunds or recovered by the receiving bank24. In the last full year before the voluntary code launched, just 19% of the amount lost by individuals was returned to them, and across all the firms UK Finance collected data for in 2019, just 26% of the amount lost by victims of APP fraud was reimbursed25.
Speed is part of the design. Most APP fraud victims are reimbursed within five business days under the consistent minimum standards26. The official statistics bear that out: 82% of claims were closed within five business days and 98% within 35 business days between 7 October 2024 and 31 March 20262. Scam victims must be reimbursed within five UK business days unless the bank or payment provider needs to gather more information9.
On interest and tax, the sources give no figure. Whether interest is added on top of an award, and whether it counts towards the ombudsman's limit, is not stated in the sources here, so no answer can be given. The same applies to the tax treatment of compensation: there is no fact in the sources on it. Both are questions to put to the ombudsman and to HMRC directly.
Where the ombudsman's award limit stops: going to court
The ombudsman's limit is the end of its power, not the end of your options. If your loss exceeds the award limit that applies to your complaint, the ombudsman can order up to that limit and no more7. The remainder would have to be pursued through the courts, which is a separate process with its own costs, timescales and risks.
There is a history here worth knowing, because it explains why the numbers in circulation differ. The regulator consulted on the maximum reimbursement limit for APP scam claims and confirmed an upper limit of £415,000 for claims made via Faster Payments and CHAPS in December 202327. The scheme that actually came into force on 7 October 2024 set the cap at £85,000 instead21. The higher figure was consulted on and confirmed at one stage; the lower figure is what applies.
That divergence is why a reader may see £415,000, £350,000, £445,000 and £455,000 in different places. They are not all describing the same thing. The £415,000 was a proposed scheme cap27. The £350,000, £445,000 and £455,000 figures relate to the ombudsman's award limit at different points7. The £85,000 is the scheme cap that applies to claims1.
For a loss above £85,000, the practical sequence is: claim under the scheme up to the cap, complain to your bank about the rest and about how it handled the claim, refer to the ombudsman if you are unhappy, and treat anything above the ombudsman's award limit as a matter for legal advice.
Sources27 cited
- What to do if you're the victim of a bank transfer (APP) scam Which?
- APP scams reimbursement dashboard Payment Systems Regulator, 2026
- APP guide Take Five
- How to open a bank account online Which?, 2026-04-23
- UK Finance Fraud Report 2026 UK Finance, 2026-06
- Open banking: sharing your financial data Which?, 2026-03-06
- Which? response to the PSR's consultation on Faster Payments APP scams Which?, 2023-12
- Wedding insurance complaints Financial Ombudsman Service, 2026-09-27
- What to do if you're the victim of a bank transfer (APP) scam Which?, 2026-05-12
- How to make a claim and the exclusion list Aldermore, 2026-09-26
- Fighting authorised push payment fraud: a new reimbursement requirement Payment Systems Regulator, 2026-09-26
- Compensation Financial Ombudsman Service, 2026-10-01
- Who we can help Financial Ombudsman Service, 2026-09-27
- Authorised push payment scam first direct, 2026
- What is an APP scam Barclays Private Bank, 2026
- DISP 2.7: Complaints about authorised push payment fraud Financial Conduct Authority, 2025
- APP scams policy statement Payment Systems Regulator, 2023-12
- Ombudsman news issue 145 Financial Ombudsman Service, 2018-08
- Using behavioural economics to understand and prevent authorised push payments fraud Payment Systems Regulator, 2024
- APP scams consultation on measures Payment Systems Regulator, 2026-09-26
- New bank transfer fraud refund scheme sees 86% of losses refunded Which?, 2024-10-07
- The investment fraud refund lottery Which?, 2024-09-29
- New rules for bank transfer fraud reimbursement from 2024 Which?, 2022
- APP scams policy statement Which?, 2020-08
- London Capital and Finance investor compensation begins Which?, 2020-02-18
- Our work on APP scams Payment Systems Regulator, 2026-09-26
- Extending Confirmation of Payee coverage Payment Systems Regulator, 2022-10












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