Electronic money (e-money) is pre-paid money you store electronically on cards, devices or online systems and use to make payments to other parties.
It includes online services like PayPal, Revolut, Tide, Wirecard and Skrill, which customers can use to pay or receive money for goods and services. The following guidance is for this kind of e-money business.
Types of complaints we see
We can look at complaints about e-money businesses from customers who could be buyers or sellers. They may complain that:
- you (the e-money business) unfairly reversed a payment
- they didn’t receive what they paid for or it wasn’t as described
- they’re unhappy about how you’ve resolved a buyer/seller dispute
- you’ve unfairly placed restrictions on their account
We can help to resolve complaints about e-money businesses, but we can’t look at complaints about buyers or sellers. This means we can’t directly resolve disputes between buyers and sellers who’ve used an e-money account for a transaction.
Sellers generally send goods or provide services once they’ve got confirmation that the buyer’s payment is in their account.
However, you may decide to reverse the payment if a buyer says they:
- didn’t authorise the payment
- haven’t received what they paid for
When we consider complaints about whether you acted fairly in reversing a payment, we’ll usually take into account:
- whether you clearly drew the seller’s attention any terms and conditions covering your right to reverse a payment
- the underlying transaction that gave rise to the payment
- the seller’s account history
Your terms and conditions may allow a buyer to claim a refund if they didn’t receive what they paid for or if it wasn’t as described.
If a buyer complains you haven’t refunded them, we’ll usually take into account:
- the terms and conditions of the buyer’s e-money account
- any relevant evidence about the goods or services, such as the seller’s original description
- if relevant, whether the goods or services were significantly different from the seller’s description
Some e-money businesses offer customers a credit facility. If a customer has used a credit facility (or credit card) to buy goods and services, they may be able to complain about the quality of those goods and services under section 75 of the Consumer Credit Act 1974.
However, section 75 might not apply if the customer has used a credit card to put funds into a standard e-money account and then used that account to buy something.
See also our guidance on goods and services bought with credit.
We can’t usually resolve a dispute between a buyer and seller that involves an e-money transaction. But if you offer dispute resolution as part of your service to account holders, we can look at a customer’s complaint about a decision you’ve made in their dispute.
We’ll look at whether you’ve applied your terms and conditions fairly (including any time limits).
We can consider a complaint where a customer says you’ve incorrectly or unfairly applied their account’s terms and conditions when restricting or stopping their account.
We’ll look at:
- what the relevant terms and conditions say and whether they’re clear and unambiguous
- how the customer has been using their account
- how long you’ve restricted the account for
- your justification for not releasing money to the customer if you’ve frozen their account
- what effect restricting or stopping the account has had on the customer
Handling a complaint like this
We only look at complaints that you’ve had a chance to look at first. If a customer complains and you don’t respond within the time limits or they disagree with your response, then they can come to us.
Find out more about how to resolve a complaint.
Putting things right
If we decide you didn’t act reasonably in reversing a payment, we’ll usually tell you to put the reversed credit back into the customer’s account – and pay interest, where appropriate.
If we agree with the customer’s complaint, we’ll usually tell you to refund them in accordance with the relevant terms and conditions.
If we find you’ve wrongly restricted a customer’s account, we’ll ask you to put things right. We may ask you to compensate the customer for any:
- losses they’ve suffered as a result of not having access to money in their account
- distress and inconvenience they’ve suffered
If we find you haven’t applied your terms and conditions fairly, we’ll look at the individual circumstances to decide on a fair resolution. For example, if a seller hasn’t received payment for goods they’ve sold and delivered, we might tell you to complete the payment.
E-money business refuses a customer’s request for a refund
Fraud and scams Banking
A customer complains that an e-money business reversed a payment made into his account
Banking Disputed Transactions
Customer complains that an e-money business prevented him getting access to his account