The supplier's bank details changed by email. A headcount decides which door you claim through.

Two things are now true at once. The £9,400 has gone, and you still owe the supplier £9,400. The bank's first answer is that you authorised the payment from your own account, so there is nothing to reverse. Most owners stop there, because the mandatory reimbursement rules that took effect on 7 October 2024 are widely read as a protection that stops at the door of a business account. That is half right. A headcount decides which door you recover the money through, not whether you recover it at all.

A regulator and a statutory instrument are both called the PSR. The Payment Systems Regulator, the economic regulator of payment systems under the Financial Services (Banking Reform) Act 2013, made the authorised push payment (APP) reimbursement requirement. The Payment Services Regulations 2017 (S.I. 2017/752) are a statutory instrument, and regulation 2(1) defines a consumer as:

A restaurant can never be that. If the reimbursement requirement had borrowed that definition, the question would be settled against every restaurant. It did not.

The definition sits in Specific Requirement 1 (July 2024), which required the Faster Payments operator to insert APP scam reimbursement rules into the scheme rules. SR1 sets the outcomes, and the scheme rules bind your bank:

The microenterprise limb is two tests joined by "and", not a choice. The money test is generous: "either an annual turnover or an annual balance sheet total" under €2 million, so one of the two is enough, though SR1 states it in euro with no conversion basis. The staff test has no alternative. Fewer than ten persons, or you are out.

The same wording appears in the Bank of England's CHAPS rules, in the proposed text located for this article. A separately drafted definition in regulation 2(1) of the Payment Services Regulations 2017 fixes the moment of testing:

SR1's parenthetical gives no test date and no counting method. It does not say whether a part-time weekend server counts as one person or a fraction of one. No first-party guidance answering that was located for this article.

ONS ad-hoc release Food services by employment size, UK: 2023 to 2025 (reference number 3495, released 24 June 2026) counts enterprises by employment size band on the Inter-Departmental Business Register. For SIC 56101, licensed restaurants: 31,615 enterprises, of which 18,920 sit in the 0-9 band, 11,745 in 10-49, 825 in 50-249 and 125 at 250 or more, with counts control rounded to base five.

So about 12,695 licensed restaurants, two in five, already employ ten or more people. That band is the ONS's own employment measure, not the reimbursement rules' test, so it indicates scale rather than settling any individual case. The money limb almost never excludes an independent restaurant. The staff limb routinely does.

If that is you, the requirement is not yours to invoke, and the ombudsman route is where the claim has to go instead.

The Financial Ombudsman Service uses a wider line. It admits a micro-enterprise in its own right under DISP 2.7.3R(2) and, separately under DISP 2.7.3R(6), "a small business at the time the complainant refers the complaint to the respondent", which the Handbook glossary defines for DISP as an enterprise which:

That closing clause aggregates. DISP 2.7.4G: "where a parent company holds a majority shareholding in a complainant, if the parent company does not meet the tests for being a micro-enterprise or a small business then neither will the complainant." A single site inside a small group can fail on the group's figures, not its own.

Subject to that, an independent restaurant failing the ten-person test will usually clear the small-business thresholds. PS25/5 calls the requirement's scope one that "largely echoes the scope of complainants who may apply to the Financial Ombudsman Service under the FCA's DISP rules", footnoting DISP 2.7.3. On the rules as served, "largely" carries the whole ten-person gap.

DISP 2.7.6R(2B) adds a relationship head for this loss:

Complaining about your own bank does not need it: DISP 2.7.6R(1) already covers a customer or payment service user. (2B) adds reach to a firm you have no relationship with: the bank that banked the fraudster.

The procedure is short, and one deadline in it is fatal. Complain to the firm first. Under DISP 2.8.2R the Ombudsman "cannot consider a complaint if the complainant refers it to the Financial Ombudsman Service: (1) more than six months after the date on which the respondent sent the complainant its final response ... or (2) more than: (a) six years after the event complained of; or (if later) (b) three years from the date on which the complainant became aware ...". Six months from the bank's final response letter is the one that catches people.

DISP 3.7.4R uprates the award limit every 1 April. Its Note table as served ends:

So for a complaint referred on or after 1 April 2026, about an act or omission on or after 1 April 2019, the maximum money award is £455,000. The widely circulated £430,000 (including on the regulator's own consumer page, untouched since October 2024) is the 1 April 2024 band.

Two qualifications go with that door. The Ombudsman decides what is fair and reasonable, not the reimbursement requirement, so the five-business-day duty and the automatic entitlement do not travel through it. No published ombudsman decision applying any of this to a restaurant was located for this article.

SR1 sets a long outer limit and a short inner one. Every quotation below is the Faster Payments text; PS25/5 calls the Bank's CHAPS rules closely aligned, not identical.

Thirteen months from the last payment, not from discovery.

It may stop the clock repeatedly while it waits for information it has asked for, but not indefinitely:

The ceiling is £85,000 per claim for both Faster Payments and CHAPS, and the bank may apply "an optional £100 excess ... (individual firms may choose to apply the excess, choose an alternative excess value up to the maximum £100 or not to use it at all)".

The rails the money moved over matter too. The requirement covers "when money is moved from one UK bank account to another over the Faster Payments system or CHAPS", and it "does not apply to civil disputes, payments which take place across other payment systems, international payments, or payments made for unlawful purposes." A real supplier who took your money and delivered nothing is a civil dispute. A criminal impersonating your supplier is an APP scam, and invoice redirection is squarely that. Card mechanics are a third thing, with their own clocks, covered in the duplicate-charge and refund timings piece.

PS25/5 (May 2025) is blunt:

The first is first-party fraud, built into what counts as reimbursable at all: a payment qualifies only "where the consumer standard of caution exception does not apply, the victim is not party to the fraud or claiming fraudulently or dishonestly to have been defrauded and the claim was made within the time limit set out in the reimbursement rules". For a restaurant the exposure is not the owner but whoever changed the payee record.

The second is what an invoice-redirection claim turns on, and it is not ordinary carelessness:

PS25/5 sets out four requirements: regard to interventions, prompt reporting within 13 months, response to reasonable and proportionate information requests, and on request reporting to the police or consenting to the bank doing so. The first is narrower than it looks:

A generic warning screen is not obviously that. No published decision applying the exception to a business claimant was located for this article, and no first-party source located here treats a Confirmation of Payee mismatch as such an intervention.

One carve-out has two limbs, not one. SR1 paragraph 4.2: the exception "does not apply if the victim was a vulnerable consumer when they made a FPS APP scam payment and this had a material impact on their ability to protect themselves from the scam." Paragraph 5.21 does the same for the excess. Vulnerability comes from FCA guidance framed around personal circumstances; whether a business claimant can be assessed as vulnerable is not something this research established.

It has not. HM Treasury's consultation response, updated 21 April 2026: "Consolidating the PSR into the FCA will require primary legislation." The same response commits to carrying the rules over, through transitional provisions "to transfer pre-existing PSR requirements, technical standards, other legal instruments, and guidance to the FCA to facilitate a smooth transition", and it names the APP reimbursement regime as an example. Reports of a Bill introduced in 2026 appear only in secondary commentary, contradicted by the Treasury page, and are treated here as not established.

Both doors are records problems before they are payment problems: proving which side of the ten-person line you sat on, and when, means holding your own figures and transaction history.

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The claim itself sits with the bank that holds your account, and no such promise is made here. What the restaurant can own is its demand and its records, and that is why managed search readiness, Restaurant and LocalBusiness schema, sitemaps, robots controls and managed search-verification setup are on every plan. Indexing and ranking remain decisions for Google.

Two more qualifying tests: the retail, hospitality and leisure rates multipliers, and the tribunal claim window doubling on 1 October 2026, which changes how long the rest of your paperwork must survive.

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