June 11, 2026|⏱️~10 minutes

By Marcus Holt

In 2026, several major markets are moving in a similar direction on payment regulation. The EU has finalized its revised Payment Services Directive (PSD3) and the Payment Services Regulation (PSR). Singapore’s Shared Responsibility Framework (SRF) has been in effect for over a year. The UK has completed its first full year of mandatory reimbursement for APP (authorized push payment) fraud. Australia is pushing ahead with an automatic reimbursement proposal.

These rules come from different legal systems and political traditions. But they share a common goal: as digital payments grow and fraud becomes more sophisticated with generative AI, how should risk and responsibility be shared so that consumers are not the most vulnerable part of the system?

One problem, different solutions

When you compare the new rules across countries, a clear pattern appears. They all target a similar risk: consumers unknowingly or unintentionally taking on financial consequences through digital payments.

This can happen in two ways. One is being defaulted into a credit product at checkout – like "buy now, pay later" without realizing it. The other is being tricked by a scammer into making a transfer – known as APP fraud.

Reports from industry and regulators show that both risks have risen noticeably over the past three to five years. A key reason is generative AI. It has made fraud much cheaper and easier to produce. Personalized scam messages, fake voices, even deepfake videos are now within reach of many bad actors.

The OECD’s 2026 Consumer Finance Risk Monitor found that 85% of regulators across 60 jurisdictions rank fraud as the top consumer risk (source: OECD, 2026). Meanwhile, global financial literacy surveys suggest only about 33% of adults worldwide have basic financial knowledge. In OECD countries, roughly 66% of adults lack basic financial literacy.

Taken together, these numbers point to one conclusion: relying on consumers’ own judgment to avoid harm is no longer enough in today’s digital environment.

Different markets have responded with different tools. China’s new rule (effective September 2026) takes a “separation” approach: non-bank payment providers cannot include loan products as a payment option, nor market them within the payment flow. The EU and UK focus more on “reimbursement and reallocation” – requiring payment service providers to compensate victims of APP fraud, and in the EU’s case, to offer human customer support. Singapore and Australia are building “cross-sector responsibility” models, bringing telecom operators and big digital platforms into the picture as co-responsible parties.

These approaches are not contradictory. They could complement each other – ex-ante separation reduces accidental debt, ex-post reimbursement covers fraud that slips through, and cross-sector sharing attacks fraud at its source.

Three forc es driving convergence

What is pushing different markets to act in such similar ways at roughly the same time? Based on industry analysis and regulatory documents, three common drivers stand out.

First, technology is changing how fraud works.

Generative AI is a game-changer. When AI can produce convincing fake voices or videos, it is unrealistic to expect ordinary users to spot the difference in a few seconds. As technology becomes more sophisticated, the burden of defense has to shift from the user to the system. This logic appears – in different words – in many of the new regulations.

Second, consumer protection is moving from “soft guidance” to “hard obligations.”

Five or ten years ago, most regulators relied on guidelines, best practices, or voluntary industry standards. But in 2026, more rules are written into binding laws, with clear penalties or compensation duties. The UK’s mandatory reimbursement scheme is a good example. It is not a suggestion – it is a quantifiable, enforceable standard. Industry observers generally agree this reflects a collective realization that self-regulation has limits.

Third, fraud prevention is becoming an ecosystem problem, not just a single-company problem.

This is very clear in several markets. Singapore’s SRF assigns specific duties to banks and telecom operators. Australia’s Scams Prevention Framework covers banks, telcos, and digital platforms. The EU’s final PSD3/PSR texts also include cross-sector liability provisions.

The logic behind this shift: most APP fraud actually starts on social media or through telecom networks. Data from the UK’s Payment Systems Regulator shows that about 87% of APP fraud originates from social media, telecom networks, or online platforms (source: UK PSR, 2025). If only payment providers bear the cost, the root of the problem remains untouched.

Early evidence from implemented rules

Although many of these rules are still new, some markets have already produced operating data.

The UK’s mandatory reimbursement scheme for APP fraud (SDR20) took effect in October 2024. In its first full year (October 2024 – September 2025), payment providers reimbursed victims £173 million. Out of 188,000 eligible claims, 88% received full reimbursement (source: UK PSR, 2025). This suggests the scheme is workable and covers most eligible victims. One open question – whether generous caps (£85,000 per claim) and fairly loose exceptions might reduce consumer caution – needs more time to study.

Singapore’s Shared Responsibility Framework started in December 2024. Data from 2025 shows: scam cases fell 27.6% (from 51,501 in 2024 to 37,308), and total losses fell 17.9% (from S$1.1124 billion to S$913.1 million) (source: Singapore Police Force, 2026). This marks the first time Singapore has seen both cases and losses drop together. It is hard to credit the SRF alone – law enforcement and public education also helped – but industry analysts generally see the SRF as a meaningful factor.

In China, the China Consumers Association reported 14,791 financial service complaints in 2025, up 118% from 6,778 in 2024. Their share of total complaints rose from 0.38% to 0.73% (source: China Consumers Association, February 2026). Some of this growth reflects greater consumer awareness, but it also points to real issues with misleading design in payment flows – exactly what China’s new “separation” rule aims to fix.

Australia’s competition and consumer commission (ACCC) reported that Australians lost about A$2.18 billion to scams in 2025 (source: ACCC, 2026). That scale of harm pushed the government to pass the Scams Prevention Framework Act in 2025, and in May 2026 to propose automatic reimbursement for losses below A$3,000 – no lengthy disputes. This proposal is still under consultation.

What this means for the industry and for consumers

For payment industry professionals and investors, these rules are putting pressure on business models. Over the past decade, a common strategy was to acquire users and traffic through low-fee or even subsidized payment services, then cross-sell higher-margin products like credit, wealth management, or insurance. China’s new rule directly blocks that practice at the payment interface. EU and UK rules raise operating costs indirectly – through higher compliance and compensation burdens. Some industry estimates suggest that large UK payment providers have set aside capital for APP fraud reimbursements equal to several percentage points of operating costs. For pure-play payment firms with already thin margins, this is not trivial.

On the other hand, these changes could create new competitive advantages. Security and compliance are becoming measurable differentiators. When everyone has to meet the same basic standards, the firms that can do so at lower cost and higher efficiency gain a trust advantage. Some leading firms are already investing in AI-driven risk scoring, clearer user prompts, and faster complaint handling. These investments cost money upfront but could become brand moats over time.

For consumers, the experience will be mixed. On one hand, payment flows may become slightly longer – more confirmation steps, more warnings, fewer preselected options. On the other hand, if something goes wrong – fraud or an accidental debt – the chances of getting your money back are much higher than before. The UK data shows that 88% of eligible claims received full reimbursement, with an average processing time within five days. That is a meaningful level of protection. Of course, rules vary across markets. The UK caps reimbursement at £85,000; Australia’s proposed automatic threshold is A$3,000. Not everyone is equally protected.

A cautious look ahead

The convergence in consumer protection for payments is likely to continue. A reasonable guess: over the next two to three years, more middleincome and developed markets will introduce similar mandatory reimbursement or crosssector responsibility rules. The Bank for International Settlements (BIS) and the Financial Stability Board (FSB) have not yet issued unified guidance on this specific issue. But given the crossborder nature of fraud – scammers exploit regulatory gaps between countries – international coordination will probably increase over time. However, that coordination is more likely to happen at the principle level (e.g., “liability follows the party best able to control the risk” and “reimbursement should have low barriers”) rather than harmonizing technical standards or compensation amounts.

A note of caution is still warranted. Legal traditions, financial structures, and enforcement capabilities vary widely. A rule that works well in London or Singapore may not fit a market where cash is still common or digital payment penetration is low, and fraud takes very different forms. So convergence will likely be directional, not uniform.

Also, we still lack longterm data on the effects of these rules. Singapore’s drop in scam cases is encouraging, but total losses remain high. The UK’s reimbursement scheme is working, but the risk of moral hazard (consumers being less careful) has not been thoroughly studied. These questions may take three to five years to answer with confidence.

Conclusion

The payment regulatory picture in 2026 shows different markets answering the same challenge in their own ways: how to balance the convenience of digital payments with consumer safety. China’s separation strategy, the UK’s reimbursement scheme, Singapore and Australia’s crosssector models, and the EU’s fullchain accountability – all are different paths to a similar judgment: consumers should not be the only party bearing risk in the digital payment system.

This does not mean global standards are just around the corner. But it does suggest that, facing technologydriven fraud, a consensus is forming among policymakers. For industry players, this means higher compliance costs – but also a chance to redefine competitiveness around trust. For consumers, this might be a sign that digital payments are moving toward a more mature, more reliable state. Whether these rules ultimately achieve their goals will depend on the next few years of practice and data.

Disclaimer: This article is for informational and discussion purposes only and does not constitute financial, legal, or investment advice. Regulatory frameworks mentioned are subject to change, and outcomes may vary by jurisdiction. The author and publisher make no representations about the accuracy or completeness of any information provided. Readers should consult qualified professionals before making financial or business decisions.

About the Author

Marcus Holt has long been concerned with the protection of financial consumers' rights and interests as well as issues related to cross-border fraud. His research and writings cover digital fraud, personal data security, and the trend of global financial regulation convergence. He has participated in several international consumer protection research projects and maintains close collaboration with regulatory agencies and cybersecurity experts. He is committed to converting complex fraud techniques and regulatory policies into clear and practical public knowledge, helping readers protect themselves in the increasingly digital financial environment.

References:

[1] OECD (2026), Consumer Finance Risk Monitor 2026, OECD Publishing, Paris. (Covers 60 jurisdictions; 85% of respondents rank fraud as top risk)

[2] Payment Systems Regulator (PSR), UK (2025), Specific Direction 20: Faster Payments APP Scams Reimbursement Requirement and associated reimbursement dashboard (2024–2025 data: £173m returned, 188,000 claims, 88% fully reimbursed; 87% of APP fraud originates from social media/telecoms/online platforms)

[3] Monetary Authority of Singapore (MAS) & IMDA (2024), Shared Responsibility Framework (SRF) Guidelines, effective 16 December 2024; Singapore Police Force (2026), Annual Scams and Cybercrime Statistics 2025 (37,308 cases, down 27.6%; losses S$913.1m, down 17.9%)

[4] Australian Treasury (2025), Scams Prevention Framework Act 2025; Australian Competition and Consumer Commission (2026), Targeting Scams Report 2025 (A$2.18bn lost)

[5] European Council (2026), final compromise texts of PSD3 and PSR (published 24 April 2026)

[6] People‘s Bank of China et al. (2026), Administrative Measures for Online Marketing of Financial Products (effective 30 September 2026)

[7] China Consumers Association (2026), 2025 National Consumer Complaint and Report Analysis (14,791 financial service complaints, up 118% from 6,778 in 2024)

[8] Deloitte (2025), Payment Trends 2026: The Convergence of Regulatory Momentum, Technological Maturity and Rising Market Expectations