Regulatory uncertainty and preparedness
AI regulation shows the largest imbalance towards uncertainty. Members should assess unresolved regulatory questions and their own readiness separately.
AI regulation shows the largest difference towards uncertainty.
The FC360 Fraud Strategy polls asked respondents which regulatory change created the greatest uncertainty for their organisation and which they were best prepared for. Among 59 people answering both questions, AI regulation showed the largest difference towards uncertainty, at 17 percentage points.
AML reform, Consumer Duty and APP fraud reimbursement showed differences in the opposite direction. These selections reveal relative judgements, rather than tested readiness. Members should examine uncertainty and preparedness separately, identifying both the questions that need clarification and the controls they can strengthen now.
AML reform leads on relative preparedness, followed by Consumer Duty and APP fraud reimbursement.
Each respondent could select only one regulatory change for greatest uncertainty and one for best preparedness. The chart therefore shows which changes stood out relative to the other options. A balance towards preparedness does not establish that controls are adequate; equally, a balance towards uncertainty does not mean respondents have taken no action.
AI regulation, cross-border compliance and crypto regulation attracted more selections for uncertainty, while AML reform, Consumer Duty and APP fraud reimbursement attracted more for preparedness.
Among the 59 respondents answering both questions, 17% selected the same change for greatest uncertainty and best preparedness. This illustrates how the two judgements can coexist: an organisation may have prepared extensively for a change while still having unresolved questions about it.
For leaders, the distinction matters when interpreting the findings. Confidence in preparations and clarity about regulatory expectations are separate considerations. Neither answer, on its own, demonstrates how effectively a firm’s controls operate in practice.
Key statistic
APP fraud remains a challenge alongside reported reimbursement preparedness
In the FC360 Fraud Strategy poll, 17% selected APP fraud reimbursement as the change they were best prepared for, while 10% selected it as their greatest uncertainty.The separate Pulse Survey asked about APP fraud as a challenge. These findings measure different things: relative preparedness for reimbursement rules and the continuing threat of fraud.
of Pulse respondents rated APP fraud as a major challenge.
Source: The Payments Association Pulse Survey, 2026.
37% rated current rules’ effectiveness highly, compared with 25% for industry readiness for upcoming regulation.