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€179m lost. The question is whether firms are keeping pace.
The latest payment fraud statistics published by the Central Bank of Ireland should be a wake-up call for the sector.
Fraudulent payments reported by Irish resident payment service providers increased by 27.2% in 2025, reaching €179.04m. Perhaps more concerning is that manipulation of payer fraud, broadly encompassing authorised push payment fraud where customers are deceived into authorising payments, accounted for 45% of total payment fraud by value in 2025. Cross-border transactions accounted for 69.8% of total fraudulent payment value, equivalent to €124.89m.
What makes these figures particularly significant is that the number of fraudulent payments increased by only 0.3%, while their overall value rose by 27.2%. In other words, fraudsters appear to be becoming more effective and targeting higher value transactions. The average fraudulent e-money transaction more than doubled year-on-year, while credit transfer fraud continues to account for some of the largest losses across the market
For many firms, this is no longer just a fraud issue. It is becoming a governance issue.
The real message behind the numbers
At the same time as publishing these statistics, the Central Bank has been sharpening its focus on how payment and e-money firms manage growth.
In its July 2026 Payments & E-Money Newsletter, the regulator highlighted instances where firms' growth ambitions had outpaced their control frameworks, governance arrangements and local operational capacity. The Central Bank also identified significant inconsistency in how firms engage with it regarding material business-model changes, including substantive changes to products, services, distribution arrangements, growth projections, risk profiles or target markets.
This is an important shift. Historically, firms often viewed fraud management, product growth, compliance and governance as separate topics owned by different teams. The Central Bank increasingly appears to be viewing them as interconnected.
A payments firm launching new products, entering new markets, onboarding significantly higher transaction volumes or partnering with new distributors may also be increasing its exposure to fraud, financial crime, safeguarding risks and operational disruption. Regulators are therefore asking a more fundamental question:
Does the firm's control environment scale at the same pace as its business model?
What we're seeing in practice
Based on our work across the market, we see a number of recurring risks that firms should actively test:
- Transaction volumes are growing faster than fraud monitoring capabilities.
- New payment channels are being introduced before governance frameworks are fully adapted.
- Firms are relying heavily on third-party providers without fully understanding downstream risk exposures.
- Fraud prevention teams are spending more time responding to incidents than proactively identifying emerging threats.
- Boards and management teams often receive extensive operational reporting, but limited insight into evolving fraud trends, customer impacts and control effectiveness.
What should firms be thinking about now?
The firms that will be best positioned over the next 12 to 24 months are unlikely to be those with the fastest growth story.
They will be the firms that can demonstrate that governance and control capabilities are growing alongside the business.
From an RSM perspective, there are four areas worth prioritising:
| Reassess fraud through a growth lens | Many organisations review fraud risk annually. However, firms should also consider whether upcoming growth initiatives, new geographies, new partners or expanding customer segments materially change their fraud exposure. |
| Challenge whether "business as usual" is still appropriate | The Central Bank has made it clear that boards should define what constitutes a material business model change and support that assessment with an appropriate risk evaluation. A business that looks very different from 12 months ago may require different governance, reporting and control structures. |
| Focus on customer outcomes after fraud events | Firms should also consider customer outcomes after a fraud event, including the timeliness of their response, the clarity of customer communications and the effectiveness of investigation and remediation processes. |
| Test whether operational capacity can absorb future growth | Growth plans often focus on revenue, customers and market share. Firms should apply the same level of challenge to fraud operations, transaction monitoring, investigations, compliance oversight, safeguarding processes and management information. |
Colm Laird, Partner
“The next competitive advantage in payments may not be growth itself, but the ability to demonstrate that growth remains controlled.”
The takeaway
Fraud is becoming more sophisticated, losses are increasing, and regulators are paying closer attention to whether firms' governance and operational capabilities are keeping pace with growth.
Click here to access the full PDF version of our Financial Services Perspectives briefing - November 2026.
