Summary record of the fourth session of the Fair Play Council

Session details

The fourth session of the Fair Play Council was held on 16 May 2026 in two Open Table sittings. The Asia-Pacific sitting took place from 06:00 to 07:30 UTC. The Europe, Africa and Americas sitting took place from 16:00 to 17:30 UTC. The Chair presided over both sittings. The record consolidates their discussions and decisions.

The surviving session record does not provide a verified attendance count for either sitting or for the combined session. As of 16 May, the Fair Play Council had 83 members from 33 countries. Those figures describe the Council’s membership, not the number who attended this session. The Council had received 108 reports from 34 countries; these figures describe the evidence base available for discussion and are not attendance figures.

Agenda

1. Opening remarks and confirmation of the session’s purpose.
2. Review of evidence received under FP-001, the Council’s call for evidence on business fraud.
3. Discussion of reported payment-fraud situations and the five-part pattern test.
4. Review of existing guidance and possible areas for further evidence.
5. Decisions, action items and arrangements for the next session.

Summary of proceedings

1. Opening. Chukwudi Umeh opened the session and recalled that FP-001 remained at the evidence-gathering and review stage. He stated that the task before the Council was to describe practices and problems consistently, not to reach conclusions about individual banks, payment providers or businesses. He reminded participants that member accounts should not identify a member’s own business or make unsupported allegations about named firms. The Chair said that any eventual proposal would have to follow the Assembly’s process: reports, a five-part pattern test, a draft fix, public consultation, an Assembly ballot and letters to the relevant chief executives.

2. Evidence received. The Chair reported that the Council’s evidence base comprised 108 reports, submitted from 34 countries. The median amount reported at stake was approximately US$4,280. He noted that the reports came from businesses of different sizes and locations, and that the Council should not treat the number of reports as proof that every reported practice occurred in the same way or with the same cause. Members were asked to distinguish what they had directly experienced from what they had learned from another person or source.

3. Changed payment instructions. Nneka Okafor of Enugu, Nigeria, described a member account concerning an invoice whose payment details had changed shortly before payment. She said the account raised questions about how a small business checks revised instructions when a transaction is already due and the apparent sender resembles a familiar supplier. She did not identify the business, supplier or payment provider. Ms. Okafor proposed that future evidence collection record whether the change was received by email, messaging service or another channel, and whether the member confirmed it through a separate contact route.

4. Pressure and timing. Daniel Mensah of Kumasi, Ghana, summarized a report in which a business owner was urged to make a payment quickly to avoid a delay in work. He said that urgency could be relevant to how a fraudulent request is assessed, but cautioned against treating urgency alone as proof of fraud. He recommended recording the time available to verify the request, the value and destination of the payment, and whether the business had an established process for checking a change in payee details.

5. Payee-name checks. Amina Yusuf of Nairobi, Kenya, described a member’s difficulty in determining whether the name presented during a transfer corresponded to the intended recipient. She asked the Council to examine what information a business sees before confirming a payment and whether a mismatch or uncertainty is communicated in a way that can be acted upon. She emphasized that a useful standard should consider small businesses’ ability to pause a transfer and obtain assistance, rather than presuming access to specialist fraud staff.

6. Recovery after payment. Kwame Boateng of Accra, Ghana, summarized an account in which the member sought help after discovering that a payment had gone to an unintended recipient. He said the report raised separate questions about how quickly a payment provider can be contacted, what information the business must provide, and whether an attempted recall is communicated to the customer. He recommended that evidence distinguish between a request to stop a pending payment, a recall after settlement and a request for reimbursement. Members agreed that these outcomes should not be grouped together in the evidence record.

7. Cross-border situations. Thandiwe Mokoena of Johannesburg, South Africa, described a report involving a payment connected with a counterparty in another country. She noted that cross-border transfers may involve different providers and response processes, making it important to record where the sending and receiving accounts are held without publishing identifying account information. She asked the evidence team to capture whether a case was domestic or cross-border and what response, if any, the member received after reporting it.

8. Business email compromise. Miguel Santos of Porto, Portugal, summarized a member account in which a message appearing to come from a known contact requested a payment-related change. He said the record should state how the member later identified the message as suspicious, whether the account or correspondence was compromised, and what steps were taken to notify the relevant provider. He cautioned that the Council should not assume that a member could identify the compromise before making the payment.

9. Evidence quality and corroboration. Grace Njeri of Mombasa, Kenya, asked that the Council record the source of each account and whether supporting material was available, such as a payment confirmation, a provider’s case reference or correspondence about a recall. She stressed that members should be able to submit evidence without disclosing personal or account details in a public forum. The Chair agreed that the evidence process should separate confidential supporting material from summaries used in Council discussion.

10. Small teams and internal checks. Leila Haddad of Tunis, Tunisia, described the difficulty of maintaining a multi-person approval process where a business has few staff or the owner performs several roles. She recommended that the Council consider proportionate verification practices that do not depend on a business having a dedicated finance department. She also asked that future evidence collection note whether the business had a written payment-check procedure and whether that procedure was practical in the circumstances described.

11. Existing UK protections. The Chair referred members to the United Kingdom’s APP fraud reimbursement protections as an existing case of a defined reimbursement framework. The protections, in force since 7 October 2024, cover eligible consumers, micro-enterprises and charities, set a maximum reimbursement of £85,000 per claim, divide the cost between sending and receiving payment service providers, and exclude international payments.¹ The Chair stated that the case could inform questions for evidence gathering but was not a decision that the same rules should be adopted elsewhere. Members agreed that any comparison should record differences in eligibility, payment type, geography, liability and claims process.

12. Prior Council material. Members noted the relevance of the Council’s call for evidence, RC/FP/2026/1, and its open letter on verifying changed invoice instructions, RC/FP/2026/20. The Chair clarified that the open letter was a practical warning and did not substitute for a Council standard. The session did not approve new wording for either document.

13. Five-part pattern test. The Chair reviewed the five required dimensions: Volume, Frequency, Consistency, Spread and Corroboration. Members considered how the dimensions could be applied without conflating the number of reports with the frequency of incidents in the wider population. They also discussed the need to distinguish similar descriptions from genuinely consistent underlying practices. The Council did not vote on whether FP-001 had passed the pattern test. No conclusion was reached on the existence or scope of a sufficiently established pattern.

14. Possible areas for continued examination. In discussion, members identified payee-name verification, rapid contact and recall processes, communication after a fraud report, reimbursement eligibility and treatment of cross-border payments as subjects for continued evidence gathering. These were recorded as lines of inquiry, not as agreed requirements or a draft fix. Members stated that the Council should seek evidence from businesses with different team sizes and from a range of countries before framing recommendations.

15. Confidentiality and public reporting. The Chair asked members to avoid posting account numbers, payment references that could identify a case, personal contact details or unredacted correspondence in public materials. The evidence team was asked to provide a secure route for supplementary material and to prepare public summaries that do not identify members or their businesses. Members may choose to occupy a public seat, but anonymity remains the default unless a member elects otherwise.

16. Decision on the stage of work. The Council agreed that FP-001 would remain in evidence review. It did not approve a draft standard, open a public consultation or recommend an Assembly ballot. It did not make findings about any named company or payment provider. The Chair recorded that a later decision on the pattern test would require a documented assessment against all five dimensions and a clear account of the supporting evidence.

Decisions and action items

1. Evidence coding. The Council agreed to organize incoming FP-001 reports using the five pattern-test dimensions while preserving the distinction between the reported event, the member’s interpretation and any corroborating material. Owner: Fair Play Council evidence team. Timing: before the next session.

2. Additional evidence prompts. The evidence team will prepare supplementary prompts covering changed payment instructions, payee-name checks, time to contact a provider, recall attempts, reimbursement outcomes and whether a payment was cross-border. The prompts will request only information relevant to the issue and will warn members not to submit unredacted account details in public. Owner: Fair Play Council evidence team, under the Chair’s oversight. Timing: for circulation before the next session.

3. Confidential supporting material. The Chair will ask the Secretariat to confirm a suitable confidential submission route for supporting documents and to clarify how public summaries will be separated from identifying material. Owner: Chukwudi Umeh. Timing: before the next session.

4. Comparative protections. Members wishing to contribute cases of existing fraud-reimbursement or payment-verification arrangements may submit a short description with the relevant jurisdiction and scope. Such cases will be treated as comparative material, not as an endorsement or proposed rule. Owner: Council members; compilation by the evidence team. Timing: ongoing.

5. Pattern-test note. The Chair will ensure that a future assessment of FP-001 addresses Volume, Frequency, Consistency, Spread and Corroboration separately and records uncertainties. No draft fix will be prepared until the Council has completed the pattern review and agreed that the evidence supports proceeding. Owner: Chukwudi Umeh and the Fair Play Council. Timing: after review of the evidence.

Next session

The next Fair Play Council Open Table session was set for June 2026. The exact date and the UTC times for its sittings were to be confirmed in the notice issued by the Secretariat. The proposed agenda will include a review of coded FP-001 evidence,

progress on the supplementary prompts and consideration of whether the record is sufficiently developed for a five-part pattern-test assessment.

The Chair closed the session by thanking members for contributing accounts without identifying their businesses or the firms involved. He reiterated that the Council’s next task was to improve the quality and comparability of the evidence, and that no conclusion should be represented as adopted policy before the required review and Assembly process had taken place.

Source

Notes and sources

1. Payment Systems Regulator, APP fraud reimbursement protections for consumers. The scope and terms described above are the protections stated on the source page. ↩

Sources

1. Payment Systems Regulator — APP fraud reimbursement protections