Revolut Ltd · DRN-6287068

The complaint Miss I complains that Revolut Ltd did not reimburse the funds she says she lost to a scam. What happened Miss I was looking to purchase some flights, and she found a travel agent online. After messaging the agent, she agreed to purchase two return tickets via a specific airline carrier. The agent agreed to a payment plan meaning Miss I sent £1,696 on 8 July 2025 and another £1,696 on 8 August 2025. Miss I says that the agent later told her they could no longer offer flights with the airline carrier she had requested, and instead offered her some alternative options, however these were on dates that Miss I could not get annual leave for, so they were unsuitable. Miss I therefore asked for a refund, and when she did not receive one, she raised a scam claim with Revolut. Revolut issued a final response letter in which they explained this was a civil dispute between Miss I and the travel agency, so they did not agree to reimburse her. The complaint was referred to our service and our Investigator assessed it under the relevant schemes. Having done so, they agreed that this met the bar of a civil dispute between Miss I and the travel agent. This is because they felt Miss I had paid a legitimate provider for a service that she ended up being dissatisfied with, but they did not think the evidence suggested the travel agent set out to defraud her. Miss I disagreed with the outcome as she still felt it was suspicious that she received neither a refund nor the flights. As an informal agreement could not be reached, the complaint has been passed to me for a final decision. What I’ve decided – and why I’ve considered all the available evidence and arguments to decide what’s fair and reasonable in the circumstances of this complaint. Having thought very carefully about Revolut’s actions, I agree with the findings set out by our Investigator. I do appreciate how disappointing this will be for Miss I but, whilst I’m sorry to hear of what’s happened, I don’t think I can fairly hold Revolut liable for her loss. When considering what is fair and reasonable in this case, I’ve thought about the relevant rules that were in place at the time this disputed payment was made. From 7 October 2024, Payment Services Providers in the UK, like Revolut, have been bound by the Faster Payments Scheme (FPS) and the CHAPS reimbursement rules. Under these rules, most victims of Authorised Push Payment (APP) scams should be reimbursed – but “private civil disputes” are not covered. I’ve therefore considered whether what has happened between Miss I and the travel agent meets the reimbursement rules’ definition of an APP scam or could more reasonably be classed as a civil dispute. The rules define an APP Scam as: “Where a person uses a fraudulent or dishonest act or course of conduct to manipulate, deceive or persuade a consumer into transferring funds from the consumer’s relevant account to a relevant account not controlled by the consumer, where:

-- 1 of 2 --

• The recipient is not who the consumer intended to pay, or • The payment is not for the purpose the consumer intended” By contrast, a private civil dispute is defined as a “dispute between a consumer and payee which is a private matter between them for resolution in the civil courts, rather than involving criminal fraud or dishonesty”. So, in order to consider what has happened here as an APP scam, I would need to be satisfied that it involves criminal deception. The evidence for this would therefore need to be convincing. I understand Miss I has concerns about the travel agent, because she did not receive the tickets she had initially agreed upon, and she did not receive a refund either. But from what I have seen, I do not think the evidence I have seen suggest the travel agent set out to defraud her from the outset. Miss I has said that the flights she initially paid for were no longer available, and she was not happy with the alternative options provided to her. I can see that the travel agent has continued to engage with Miss I even after she raised a scam claim with Revolut, and when Miss I accidentally sent the agent further funds in November 2025, they sent the funds back to her. This therefore does not follow the usual pattern of a scam where the perpetrator will ordinarily cut all contact as soon as they have received the funds. The company Miss I paid was registered on Companies House and had an active online webpage. I have received information from the account provider of the beneficiary bank account. While I cannot go into detail about what these contain, I can confirm that the account activity is consistent with what I would expect to see from a travel agent. So, I do not think the receiving bank statements indicate that the travel agent was operating a scam operation. This, along with the continued contact with the agent even after the scam claim was raised and the returned funds that Miss I sent them by accident all indicate that the travel agent did not set out to criminally deceive Miss I. I also have to consider that from what Miss I has said, it is plausible that the tickets she had initially agreed upon were no longer available and that she was offered an alternative. However, Miss I says she was unable to accept the alternative due to issues with annual leave from work. I therefore think it is likely that Miss I bought tickets from a genuine merchant, but due to an issue with the flights that were initially selected and a disagreement that followed the relationship between the parties broke down. This would therefore fit the description of a civil dispute between Miss I and the travel agent, rather than a scam situation where the travel agent set out to intentionally defraud Miss I. I understand this situation is very frustrating for Miss I, as she has not received the tickets she requested and, so far, has not received a refund from the travel agent. But I don’t think her circumstances meet the high legal bar for this to be a scam and because of this, I don’t think it would be fair to hold Revolut responsible for the money she lost now. My final decision I do not uphold Miss I’s complaint against Revolut Ltd. Under the rules of the Financial Ombudsman Service, I’m required to ask Miss I to accept or reject my decision before 25 May 2026. Rebecca Norris Ombudsman

-- 2 of 2 --