Mr. John Palmer:

Sure. What the UK is doing is extremely interesting. We are monitoring it. We even talk to officials there about it occasionally to get more information. Of great interest to us is the fact that the UK will only make it mandatory when the retained EU law is revoked, PSD2 in essence, and will enact a new law to specifically allow for it. That is a little bit of an alarm bell for us, if we were to go down that path.

We are aware of the other elements of the scheme. The UK is going for a 50:50 split. It has certain logic, which Deputy Doherty has put to people in the past. The logic of the UK payment services regulator in the consultation report or its impact assessment was that this would create an incentive to invest in measures to stop push payment fraud, primarily at the receiving account end. The opening of fraudulent accounts would be stopped, which in theory should never happen anyway if anti-money laundering and know-your-customer provisions are being followed correctly, as the Deputy will be aware. However, it would not stop money mules.

One of the things I was interested in with regard to the UK logic on that was how many of the frauds in the UK are domestic, that is, in how many cases both sending and receiving entities, especially the receiving entity, are UK entities?

According to UK Finance's excellent Annual Fraud Report, 98% of APP fraud there occurs on a domestic UK payments system called Faster Payments. In Ireland we do not have a domestic payments system anymore. We used to but we now operate under the single euro payments area, SEPA, rules and there are various pan-European payment service providers, including as part of the ECB.

The only statistics I could find for Ireland were the Central Bank's payment statistics for 2021, which tell us just under 78% of domestic payments are domestic in Ireland, or in other words, payments done through Irish-resident payment service providers. By volume or number of transactions it is 78% and by value it is just over 35%. That changes the dynamic because if we were to do a domestic reimbursement scheme a bit like the UK one, we could possibly bring in that Irish-resident PSPs are required to refund something, but we would not be able to force non-Irish PSPs to do it. There might then be issues with a level playing field, competition issues and barriers to entry because obviously if a person is going to become resident in Ireland he or she will be subject to this. There are an awful lot of issues to think through and analyse.