BPFI Opening Statement to Oireachtas Finance Committee – 3rd December 2025
Opening Statement by Brian Hayes, Chief Executive, Banking & Payments Federation Ireland at the Joint Committee Finance, Public Expenditure, Public Services Reform and Digitalisation, and Taoiseach
Good afternoon Chair, Committee Members. I am joined by my colleagues Gillian Byrne, Head of Payments, Niamh Davenport, Head of Financial Crime and Peter McGuigan, Head of EU Affairs.
Chair, it was this Committee from the preceding Oireachtas which published a landmark report on Authorised Push Payment (APP) fraud in October 2024. BPFI was pleased to contribute to the process through our engagement with the Committee. While some progress has been made on the recommendations within that report, many remain outstanding. During our opening statement, BPFI will highlight several of these recommendations and outline why their implementation is critical to protecting consumers and strengthening Ireland’s financial ecosystem.
The first thing I want to say to this committee is that financial fraud is not a victimless crime. It causes real damage to customers and has grown significantly in recent years. Banks take their responsibility to protect their customers extremely seriously. It is a priority issue for the sector.
Just last week we launched a cross-sector campaign on human trafficking focused on highlighting the exploitation of people who are trafficked into this country by criminal gangs. Banks are on the front line in spotting unusual or suspicious transactions, protecting people against bad actors and fighting financial fraud and scams.
Ireland’s banking landscape is undergoing significant transformation, driven largely by accelerating digitalisation and evolving consumer expectations. The Department of Finance’s Consumer Sentiment Survey 2025 highlights the scale of this shift: 88% of Irish consumers now engage with online banking services, and more than half identify mobile apps as their primary channel for interacting with their financial provider. The adoption of neo banking services also continues to rise, with 43% of adults using these platforms at least occasionally. The survey also shows that most customers here in Ireland are multi-banked, as is the case across the EU.
The most recent BPFI Payments Monitor shows that almost 60% of contactless payments are now made via mobile wallets, and overall, contactless usage accounts for nearly 88% of point-of-sale card transactions. These figures demonstrate the pace of change but also and the importance of fostering a dynamic financial ecosystem.
Fundamental to our mandate as BPFI is to support banking competition in Ireland and to improve the landscape so that new banks can enter the market and offer new products and services. BPFI strongly supports enhanced competition and the innovation it brings for consumers and the wider financial sector. Whether a bank is a fully digital bank, a more traditional bank or something in between – it must comply with all of the various regulatory frameworks within the Irish and EU market. Equally all payment institutions and e-money firms must fully comply with EU regulations such as Payment Services Directive 2, including strong customer authentication and open banking standards, as well as Irish and EU anti-money laundering legislation and, when authorised in Ireland, the Consumer Protection Code.
The shift we have seen over the last decade is reinforced by developments within Ireland’s broader fintech and digital-finance ecosystem. The country has established itself as a significant hub for financial innovation, supported by a skilled workforce, strong links between financial services and global technology firms, and a stable regulatory environment. The domestic fintech sector encompasses payments providers, digital lenders, regtech firms, and embedded-finance solutions, all contributing to a diverse market landscape.
At the same time, consumer expectations continue to accelerate. Demand for frictionless payments, real-time access to financial information, and personalised digital tools is prompting both traditional banks and neobanks to expand their digital capabilities and reconfigure their operating models. The interplay of these forces – strong incumbents, new entrants, and an increasingly digital-first population – continues to shape banking and payments in Ireland.
There are of course new challenges from this innovation – most notably the increasing complexity and sophistication of fraud, the nature of which is also rapidly evolving.
Increasingly fraud is no longer characterised by criminals attempting to directly compromise bank systems. Instead, perpetrators increasingly manipulate consumers and businesses into authorising payments themselves. This is commonly referred to as Authorised Push Payment or ‘APP’ fraud.
In an APP scam, a criminal uses deception and social engineering to manipulate a victim to transfer money directly from their account into an account controlled by the criminal. Criminals deliberately impersonate trusted entities and create false urgency. Victims genuinely believe they are making a legitimate payment and as a result the payment is authorised by the customer. APP fraud takes many forms including investment scams, romance scams, accommodation fraud, and for businesses, invoice redirection and CEO impersonation.
Financial institutions have a clear role to play in preventing fraud, a responsibility which the industry takes very seriously and in which it invests heavily, both collectively at industry level and individually within each institution.
This includes sophisticated transaction monitoring and behavioural analytics, enhanced consumer authentications, and sustained investment in consumer education. Fraud prevention measures continue to evolve, leveraging artificial intelligence now embedded across many detections systems, with some providers deploying increasingly dynamic interventions and real-time warnings to protect customers at point of payment.
However, it is critical to recognise fraud does not originate within the banking system – the first sight a financial provider will have of an authorised push payment fraud is when a transaction has already taken place. The drivers of fraud are consistent across all institutions and always begin outside the financial system, when criminals make contact with victims – typically online or via telecommunications networks. Payment service providers encounter fraud only at the final stage of a much longer criminal journey.
The Central Bank of Ireland’s most recent Payment Fraud Report reinforces this position. It highlights that the fastest growing category of fraud is credit transfer fraud, which is driven primarily by social engineering. In these cases, consumers are manipulated into authorising payments from secure devices and trusted banking applications, highlighting that the vulnerability lies not in the payment system itself, but in the criminal exploitation of human behaviour.
As BPFI has consistently stated, tackling fraud requires a whole-of-system response – bringing together financial services, technology platforms, telecommunications providers, law enforcement and the State. This is cross border, cross industry and across public and private sectors working together.
The National Payments Strategy reinforces this need for coordinated actions and sets a clear direction for a more integrated national fraud response. BPFI is leading on several of its key anti-fraud commitments, reflecting the central role the banking sector plays in its delivery. However, the reality is that financial institutions cannot address this challenge in isolation. In other jurisdictions, such as the UK and the Netherlands, government-led strategies have played a pivotal role in driving alignment, accountability and resources across all sectors. Ireland would benefit from a similar coordinated approach at national level – one that complements the significant work already being undertaken by industry and ensures a unified, proactive response to close gaps and protect consumers. The Committee’s aforementioned report on APP fraud, recommended this very point: the need for a National Economic Crime Strategy to tackle economic crime and fraud in a comprehensive and collaborative way.
BPFI’s financial crime strategy is anchored on three pillars – collaboration, education and awareness, and information sharing.
- Collaboration
- BPFI is the current Chair of the first National Cross-Sector Anti-Fraud Forum established earlier this year as part of the National Payments Strategy. This forum brings together representatives from the banking sector, card schemes, tech companies, law enforcement, Government Departments, Industry Bodies, and Regulators. It is driving coordinated action through the development of shared standards, intelligence exchange and working towards a national fraud charter.
- BPFI also coordinates the Joint Intelligence Group which brings together financial institutions and An Garda Síochána to exchange intelligence on emerging fraud patterns, victim targeting and typologies.
- BPFI members participate in ComReg initiatives addressing spoof callers and phishing which have successfully blocked over 100 million scam calls from reaching Irish consumers.
- Education and Awareness
Education remains one of the most effective tools in fraud prevention reducing victimisation particularly as fraudsters continue to target consumers directly. FraudSMART, established and led by BPFI, is a national fraud awareness programme developed in conjunction with our members which aims to raise consumer and business awareness of the latest financial fraud activity and trends and provide simple and impartial advice on how best they can protect themselves and their resources from fraud.
The programme highlights fraud and scams through national media campaigns, social media, radio advertising, email alerts and direct community engagement. Our most recent campaigns have focused on investment scams, money muling, SME fraud and social engineering, working with partners such as ISME, An Garda Síochána and Google. In addition to national campaigns, FraudSMART has launched Scamchecker.ie – a free online tool that allows consumers to check the legitimacy of a website or link providing early-stage protections and helping consumers to verify suspicious links and avoid contact with fraudulent sites.
FraudSMART currently has nine participating members including domestic banks, digital banks, An Post and Credit Unions with support from An Garda Síochána.
- Information Sharing
Information sharing is the linchpin of fraud prevention at scale. Shared fraud databases have proven highly effective in other jurisdictions, including the UK and across Europe. Ireland urgently needs to follow suit. Our efforts to establish an Irish shared fraud database are stalled because enabling legislation has not yet been enacted. Without statutory authority, banks cannot exchange sensitive fraud-related data under GDPR, leaving a critical gap in our national fraud response.
Upcoming EU and Irish regulatory changes will provide the legal clarity and governance required for shared fraud intelligence, but swift action is essential. Real-time intelligence sharing on known fraud typologies, compromised accounts and emerging risk indicators allows financial institutions to intervene earlier and with greater accuracy. The benefits extend beyond prevention: it assists law enforcement in investigations and prosecutions and protects customers whose identities may have been compromised.
We strongly welcome the Department of Justice’s progress on this legislation and urge its swift enactment.
Payment Service Regulation
Members may be aware of the provisional agreement reached last week by the European Council and the European Parliament on the new Payment Services Regulation and Directive.
BPFI welcome the significant decision to adopt stricter provisions that require online platforms to verify the regulatory status of advertisers offering financial products to EU consumers. This is a critical intervention which tackles fraud at its true point of origin – before a victim is ever targeted. BPFI has actively advocated for this reform for over 18 months with the support of our members and the Department of Finance. Its adoption represents a major shift towards systemic fraud prevention beyond the banking perimeter and recognises that platforms must form part of the anti-fraud architecture.
Conclusion
The rapid digital transformation of Ireland’s financial services sector, driven by technological innovation, evolving consumer expectations and the emergence of new banking models, offers clear benefits to consumers and the wider economy. At the same time, it introduces new challenges especially in the area of fraud prevention. Ultimately, it is only through a coordinated, whole-of-system response that the sector can effectively combat the evolving threats posed by digital fraud, supporting a safe, competitive, and innovative banking environment for all.
Watch back the Oireachtas committee hearing here: Oireachtas committees video archive – Houses of the Oireachtas
