£3.78m Fine for Bank of Ireland UK’s CoP Failure

Why It Matters

Missing CoP not only exposed millions of customers to fraud but also triggered a multi‑million‑dollar penalty, highlighting the financial and reputational stakes of compliance in the UK payments ecosystem.

Key Takeaways

• Bank of Ireland UK fined £3.78m ($4.8m) for missing CoP deadline
• Over 1.14 million payees processed without name‑checking, covering £6.9bn ($8.8bn) transactions
• Original penalty £5.4m reduced 30% after early settlement
• CoP aims to curb APP fraud, costing UK £450.7m ($572m) in 2024
• PSR will transfer duties to FCA, concentrating enforcement risk for payment firms

Pulse Analysis

The Payment Systems Regulator’s £3.78 million fine against Bank of Ireland UK marks a watershed moment for UK payment‑service providers. While the regulator initially set a 31 October 2023 deadline for Group 1 firms to deploy Confirmation of Payee, the Irish bank lagged until January 2025, leaving over a million payees unprotected. This delay exposed the institution to heightened fraud risk and forced it to shoulder a penalty that, even after a 30 percent settlement discount, represents a substantial hit to its bottom line. The case illustrates how regulatory timelines are non‑negotiable, especially as CoP becomes a cornerstone of the UK’s anti‑fraud architecture.

Confirmation of Payee is designed to stop authorised push‑payment (APP) scams by matching the payer‑entered name against the beneficiary’s records before a transfer clears. In 2024, APP fraud inflicted £450.7 million ($572 million) in losses across the UK, and the first half of 2025 saw £257.5 million ($327 million) in losses, accounting for 41 percent of all fraud losses. Coupled with the mandatory reimbursement scheme that obliges banks to repay victims up to £85,000 ($108,000) per incident, the financial incentives for swift CoP adoption are clear. Banks that fail to implement the safeguard not only risk direct fraud losses but also face costly reimbursements and eroding customer trust.

The regulatory landscape is shifting as the PSR prepares to hand its enforcement remit to the Financial Conduct Authority. This consolidation will likely intensify scrutiny, given the FCA’s broader powers and proven enforcement record. For compliance teams, the Bank of Ireland episode serves as a cautionary tale: early planning, rigorous project tracking, and clear accountability are essential to avoid punitive fines and reputational damage. As the UK tightens its anti‑fraud framework, firms that embed CoP into their transaction‑monitoring suites will be better positioned to protect customers and preserve profitability.