Survivors Call for Fraud-Proof Payment Reform

Scam Victim Alliance (SVA) is a not-for-profit organization of survivors with lived experience of scams and cyber-enabled fraud. We welcome the opportunity to provide this submission to the Reserve Bank’s (RBA’s) call for submissions2 on Merchant Card payment costs and surcharging.

We believe Australia’s payment system must be safe by design and come at as little cost as possible to consumers, who drive the engine of our economy. Fraud in instant payments is 10x higher3 than regular credit transfers and despite claims by card schemes they are ‘secure’, PayDay News reports payment fraud as a $1b problem4.

Cyber-enabled deceptions are rampant across payment systems with victims increasingly being deceived into initiating payment. We urge the Reserve Bank to consider this rising fraud problem – particularly business email compromise and ghost tapping issues – as it considers submissions for card payments and surcharging.

Efficiency and competition in payments must not come at the cost of consumer vulnerability to global transnational scamming. Interpol has called financial crime a global crisis5. We believe Australia is losing more per capita than comparable nations ($74 per head in 2024 compared to the UK’s $36 per head) to deception and organised scams. We ask the RBA to be aware that Australia's payment and financial systems need industry regulation and controls to stop this scourge. Right now, corporations deny all liability and make victims bear the cost. This is not acceptable when people pay surcharges to participate in the digital payments system.

Surge in card-not-present payments: GHOST TAPPING & OTHER FRAUD MUST BE ADDRESSED

A payment type of high concern is ‘ghost tapping’6, where Google Pay and Apply Wallets are mysteriously used by fraudsters. Financial institutions and the Australian Financial Complaints Authority lay the blame for these frauds at the consumer, who do deliver informed consent to these transactions, yet wear the cost.

A community member with a Commonwealth Bank-linked Google Pay wallet experienced more than 20 fraudulent payments, 5 card replacements and losses greater than $10,000. He was never told how the compromise occurred, only that “he released the codes and authorised the payments”. No evidence was provided by his bank, yet determination 12-00-1102187 makes him liable.

Another community member Ian Williams7i experienced the same Google Pay issue, yet had police evidence to prove other criminals made the transactions that his bank NAB said he authorised. He has represented himself in court to fight this matter to hold powerful corporations to account.

We support the RBA’s reform direction and request a focus on real-time fraud risks, safety transparency, and shared accountability across all actors in the payments ecosystem to better manage fraud.

Surcharging can serve as a friction point that prompts consumers to pause and verify the payment process, which is a crucial safety feature in digital payment environments.

SVA urges the RBA to weigh payment safety as an equal pillar alongside competition and efficiency. Simpler, safer, and more transparent payment processes and costs should be prioritised for consumers, including things like:

First-time payment holds (enabling fraudulent payments to be easily recalled)

Certain high risk payments such as superannnuation, property or purchases for large items like cars or renovations should have risk scoring and opt-in payment delays.

We believe innovation in fraud protection must be a consideration in any regulation to ensure fast-changing payment frauds can be disrupted by industry, who should bear the cost rather than push liability on to consumers.

We ask that any savings from payment surcharges are reinvested into consumer safety mechanisms, such as those listed above. We support any move that shifts incentives toward fraud prevention and helps institutions and payment providers make the digital economy safer.

We would also suggest global payment giants be required to align with Australian standards and participate in domestic scam prevention data sharing. We support phased implementation to reforms, but strongly urge scam mitigation measures be fast-tracked given the extent of losses being experienced by Australians.

Consumers deserve to know how their payment service providers rank in preventing scams and believe they should be required to report scam incident rates, funds recovered and risk mitigation practices.

We would like financial payment providers – or government – to develop an industry-wide Payment Safety Scorecard, similar to energy efficiency ratings, that genuinely help consumers reward corporations and payment providers that prevent financial crime and scams.

In conclusion, we would like to see Australia's payment systems do more to protect consumers from scams and financial crime. While innovations like real-time payments offer convenience, they also accelerate the fraud cycle, leaving victims little recourse. Scam Victim Alliance (SVA) welcomes the Safety by Design (SbD) principles outlined in AusPayNet’s July 2025 report, and we urge regulators and industry stakeholders to consider mandatory frameworks to protect people.

The transformation of Australia’s payment infrastructure must be built on trust, safety, and accountability. Technology has enabled sophisticated scams; now, it must be used to stop them. Survivor-led design, embedded safety features, and system-wide transparency can prevent life-altering financial losses. We welcome the opportunity for ongoing open dialogue and look forward to constructive reform to reduce the harm Australian scam victims experience.