Ecommpay warns UK fraud review ignores platform liability

Ecommpay has criticised the UK government's consultation on unauthorised fraud as too limited, arguing that it fails to address platform liability.

The intervention came from Willem Wellinghoff, chief compliance officer, as ministers gather evidence on the scale and drivers of fraud in the UK. He cited official figures showing that fraud accounts for 46% of all crime recorded in the Crime Survey for England and Wales, with an estimated economic and social cost of £14.4 billion.

Unauthorised fraud remains a significant part of that picture despite a modest fall in transaction numbers. According to figures cited by Wellinghoff, 3.81 million unauthorised-fraud transactions were recorded in 2025, down 5% year on year. Losses still totalled £703.4 million, while case volumes rose 11%.

One area drew particular attention: SIM-swap cases are up 1,055% since 2024, which Ecommpay said underlines the need for a broader policy response.

"Last month the government launched a call for evidence on unauthorised fraud in the UK. This set out the scale of the problem: fraud now accounts for 46% of all crime recorded in the Crime Survey for England and Wales, an estimated £14.4 billion in economic and social cost. And whilst the 3.81 million unauthorised-fraud transactions in 2025 were down 5% year-on-year they still caused £703.4 million in losses, and an 11% rise in case volume. What is especially concerning is the fact that SIM-swap cases are up 1,055% since 2024," said Willem Wellinghoff, chief compliance officer at Ecommpay.

Ecommpay welcomed the consultation but said it should go beyond measuring losses and reimbursement. The company's argument centres on where fraud begins and whether online platforms and other intermediaries should bear more responsibility for preventing scams and account takeovers before money is lost.

Policy gaps

Wellinghoff said recent developments in artificial intelligence and digital tools were increasing the speed and scale of fraudulent activity. In his view, policy has not kept pace.

"As the digital economy continues to evolve, it is clear that more needs to be done to protect individuals and businesses; the call for evidence is therefore welcome. However, I have a concern that it doesn't go far enough. Our own Fraud Report, published earlier this year, echoed the government's view that AI and digital advances are enabling fraudulent activity on an epic scale, and at a far greater pace than the solutions to tackle it," said Wellinghoff.

The comments add to a wider debate in the payments and banking sectors over the balance between reimbursing fraud victims and intervening before fraud occurs. Consumer groups and many industry participants have defended mandatory reimbursement rules as a way to improve outcomes for victims. But they have also raised questions about how liability should be shared across the chain of firms involved in digital transactions.

Ecommpay supports the reimbursement regime but sees it as incomplete without action on the systems and services where fraud can begin. The rise in SIM-swap fraud featured heavily in that argument.

"I firmly believe that the mandatory reimbursement regime was the correct policy direction with the latest fraud data bearing that out. The challenge is that the issue of platform-liability remains unresolved. Indeed, the 1,055% rise in SIM-swap fraud makes it more urgent, not less," said Wellinghoff.

Broader scope

Ecommpay said it would submit evidence to the consultation, focusing on what it sees as weak points in the current approach. It also argued that some fraud categories are receiving too little attention.

Card-not-present fraud and acquiring fraud were identified as examples that should feature more clearly in the government's review. Those categories affect merchants and payment providers as well as consumers, and can sit outside the more visible debate around authorised push payment scams and reimbursement rights.

Wellinghoff set out that position in the company's final comment on the issue. "Ecommpay will be making its submission to the call for evidence to provide our own insight on where we think the weaknesses and risks exist. At the centre of our response will be the view that reimbursement fixes the symptom after the fact. What is urgently needed are solutions to address the platforms where much of the fraud originates. We also believe that some fraud types have been overlooked (card-not-present (CNP) and acquiring fraud, for example)," said Wellinghoff.