Payment fraud
A supplier emails new bank details. What should happen next
Ring the supplier on a number you held before the email arrived and have a second person approve the change; if money has already gone to a new account, ring your bank's fraud team before anything else.
By Oscar CobbeCurrent as at 18 minute read18 sources
What invoice redirection and CEO fraud are
Invoice redirection fraud usually starts with an email that appears to come from a supplier you already pay. An Garda Síochána says the approach can also come by phone or other means, and FraudSMART lists the telephone, letter and fax as well as email. The message says the supplier's bank account has changed and asks you to update your records. Often it does not ask for a payment at the time. The next genuine invoice is then paid into an account the criminal controls. An Garda Síochána notes that the loss may not be noticed until the real supplier sends a reminder, and that the business still has to pay the real supplier's invoice.
CEO fraud is a similar trick, dressed as a request from inside the business. An email that appears to come from the chief executive or another senior person asks somebody in finance to make an urgent payment, and, as the Gardaí describe it, it generally insists on secrecy. The National Cyber Security Centre (NCSC) groups both under business email compromise, along with payroll diversion, where HR or payroll staff are tricked into changing the account an employee is paid into. The email can come from a real mailbox the criminal has got into, from a forged sender address, or from a lookalike domain (an address made to look like the real one) registered for the purpose.
When the email arrives
The steps below draw on advice from the NCSC, An Garda Síochána and FraudSMART, the fraud awareness initiative led by Banking & Payments Federation Ireland (BPFI). They are in the order you would take them, and each step names who advises it. They apply the same way when the request comes by letter or phone call.
- 1Do not reply to the email and do not ring any number in it. An Garda Síochána warns that the contact details in the email may put you through to the fraudster. Ring the supplier on a number you held before the email arrived: FraudSMART's guide says to use contact details held on record or the number on the company's own website. Ask the person you deal with there to confirm the change and the new account number. BPFI advises checking the IBAN (the account number) with the payee by calling a known and trusted number.
- 2Have a second person look at every request to change a supplier's bank details before the change is made. An Garda Síochána advises that every request to change bank account details is brought to the attention of a supervisor. Where one person makes every payment, there is nobody to be that second person. For that business, the call-back on a known number is the check that still applies, along with the bank's name check.
- 3Hold the first payment to a changed account until the call has been made. The NCSC advises delaying large payments by default to allow for fraud detection.
- 4Set up dual authorisation in your business online banking, so that two people approve each payment. FraudSMART advises it for every electronic payment to a third party. The NCSC advises two approvers for payments above a set amount.
- 5Read the result of the bank's name check. Since 9 October 2025, banks and payment providers in euro-area countries have had to check the name you enter against the name on the account before you approve a euro bank transfer (credit transfer). BPFI says the check may also run when you add a new payee or change an existing one in online banking. If a supplier you have paid before comes back as no match or close match, stop and ring them. BPFI advises businesses not to change the payee name to whatever the system shows unless it has been verified. The limits of the check are two sections down.
- 6Apply the same call-back when a member of staff asks to change the account their pay goes into. The NCSC gives "Please update my direct deposit details before the next payroll" as a warning sign, and BPFI's guidance for businesses says to confirm names and IBANs with suppliers, staff and partners through a trusted channel.
- 7Treat urgency and secrecy as warning signs, even from your own managing director. Among the signs of an attempt, the NCSC lists emails from executives or suppliers asking for urgent action or confidentiality, and messages asking you to bypass normal processes. FraudSMART warns of the tactic of sending the email when the supposed sender is away from the office and hard to check with.
- 8Write the procedure down and make sure everybody who can pay a supplier knows it, including whoever covers holidays. An Garda Síochána advises clear policies and procedures for checking payments, known to all employees. FraudSMART and the NCSC both advise training staff on email fraud.
The number in the email belongs to whoever sent the email
Ring a number you held before the email arrived. A match from the bank's name check does not replace that call. It only confirms that the name typed into the payment matches the account, and a fraudulent email can supply the name as well as the account number.
If the money has already gone
Speed matters most. The NCSC says most funds are unrecoverable if not flagged within the first few hours, and that stolen money is often moved quickly through money mule accounts and overseas banks.
It gives two Irish cases. In 2022 a private company had over €98,000 sent to an account in Portugal. Working with its bank, the company had the payment cancelled and all of the money recovered. In 2023 a local authority paid over €500,000 after receiving a fake invoice from a spoofed supplier email address. The payment was made without secondary verification, and the loss was not recoverable.
- 1Ring your bank's fraud team now and ask it to stop or recall the payment.
- 2Ask the bank what it is doing to recover the money. If the account number you gave was not that of the person you meant to pay, your bank must make reasonable efforts to recover the funds, and the receiving bank must cooperate (Regulation 111 of the European Union (Payment Services) Regulations 2018). If the money cannot be recovered, your bank must give you, if you ask in writing, the information it holds that you need to take legal action for it. It may charge you for the recovery if your contract with it says so.
- 3Report it to your local Garda station. An Garda Síochána asks for invoice redirect and CEO fraud to be reported to the local station and to the bank immediately. It asks for failed attempts to be reported as well, because the bogus account may be in use for other frauds of the same kind, and reporting it may prevent them. The Garda National Economic Crime Bureau takes the more serious and complex cases. The NCSC's guidance lists the NCSC as a second place to report.
- 4Keep everything. Do not delete the email. Save its headers (the technical details of where it came from), any logs and call recordings, and the transaction details, which the NCSC describes as vital for investigation and potential recovery. Keep the invoice too.
- 5Find out how the email got in. If it came from your own mailbox or a colleague's, change the password, turn on two-step sign-in, and check the mailbox for forwarding rules nobody set up. The NCSC's steps after an incident include changing compromised passwords, checking for suspicious email forwarding rules, and assessing how the attacker succeeded.
- 6If the attacker was inside a mailbox or system that holds personal data, assess it as a personal data breach. Under the GDPR, unauthorised access to personal data is a breach. You must report it to the Data Protection Commission without undue delay and, where feasible, within 72 hours of becoming aware of it, unless the breach is unlikely to result in a risk to people. If it is likely to result in a high risk, you must tell the people affected as well, with some exceptions (Article 34). Every breach, reported or not, has to be recorded. What the first 72 hours require is set out separately.
- 7Tell the real supplier what happened. The NCSC advises notifying affected parties, such as suppliers and customers, if their data or payments may be at risk, and An Garda Síochána's description of this fraud notes that the business still has the supplier's invoice to pay.
What the bank's name check catches, and what it does not
Under EU payment law, written into Irish law in 2018, the account number decides where a bank transfer goes. A payment made to the account number given counts as correctly made. If that number was not the one of the person you meant to pay, the bank is not liable for it as a faulty payment. Until October 2025 banks were not required to check the payee's name either. The Instant Payments Regulation (Regulation (EU) 2024/886) added that check. It left the account-number rule in place for a bank that runs the check as required. It added Article 5c to the SEPA Regulation (Regulation (EU) No 260/2012), which requires your bank to offer a service that checks the payee before you approve a bank transfer. Banks and payment providers in euro-area countries, Ireland among them, had to comply by 9 October 2025, and the service is free (Article 5b(2)). Banks and BPFI call it Verification of Payee.
The check runs after you enter the payee's details and before you approve the payment. The payee's bank compares the name you entered with the name on the account. If the two almost match, your bank shows you the name on the account. If they do not match, you are warned that paying might send the money to an account not held by the payee you named. BPFI says the check applies to both standard and instant SEPA payments.
The check helps against invoice redirection as FraudSMART describes it. That fraud keeps the supplier's name and changes the account number. A payment in the supplier's name to an account held by somebody else now brings up a warning before the money moves, unless the account holder's name is close enough to the supplier's to pass. The check has limits, all of them in the Regulation or in BPFI's own guidance.
- 1It warns and does not block. Banks must make sure the check does not stop you approving the payment (Article 5c(5)). They must tell customers what ignoring a warning means for liability and refunds (Article 5c(7)). A bank that has met the Article's requirements is not liable for a payment sent to the wrong payee on an incorrect account number (Article 5c(8)).
- 2A similar name can pass. An account in a name close to the supplier's can come back as a close match, showing the account holder's name, which can look like a typo. BPFI warns that an account belonging to somebody else may return a match or a close match if the name is similar. For a business, BPFI says the name is checked against the registered legal name, legal abbreviations and trade names. BPFI advises businesses to reconfirm the name with the payee through a trusted channel and to consider delaying the payment until it is clarified.
- 3A match only means the name typed matches the account. If the fraudulent email supplies a new account name along with the new account number, and that name is entered, the check compares the criminal's name with the criminal's account and reports a match. A CEO fraud payment to a new payee works the same way.
- 4Payment files can be outside it. Banks must let a business that sends many payments together, as one file, opt out of the check (Article 5c(6)). BPFI says the opt-out is subject to each bank's terms. If your supplier payments go to the bank as a file, ask the bank whether those payments are checked.
- 5Some payments are not checked at all. BPFI lists payments in other currencies, card payments, direct debits, paper payments received by post, and standing orders after the first set-up. The SEPA Regulation covers euro bank transfers where both banks are in the EU. A payment to an account at a bank in the UK is outside the Regulation's check, whether it is in sterling or in euro. BPFI says SEPA countries outside the EU and EEA, such as the UK and Switzerland, may offer the check in the future.
- 6Payment providers in EU countries that do not use the euro have until 9 July 2027 to offer the check, under Article 5c(9). If your business account is with a provider based in one of those countries, ask it whether it runs the check yet.
The email settings behind the fraud
None of these replaces the call-back. They make it harder for a criminal to sit inside your mailbox, to forge mail in your name, or to reach your staff from a lookalike domain.
- 1Two-step sign-in on every email account. The NCSC advises requiring multi-factor authentication (two-step sign-in) on all email accounts. A 2023 case study from the Data Protection Commission describes an attacker who got into a second-level school's systems, email included. The attacker sent the school's accounts administrator a fake email that appeared to come from the principal, with copies of invoices for real work showing altered bank details. The school paid, and found out when the real supplier said it had not been paid. The DPC recommended multi-factor authentication, ongoing monitoring and reminders of the school's email usage policy.
- 2Forwarding rules checked and controlled. A criminal inside a mailbox can set a rule that sends copies of its mail to an outside address. The NCSC's guidance includes blocking unauthorised forwarding and monitoring forwarding rules among its controls.
- 3DMARC on your own domain: the setting that tells other mail systems what to do with forged email in your name. The NCSC advises setting up and monitoring SPF, DKIM and DMARC. If your DMARC record asks for forgeries to be quarantined or rejected, a receiving mail system that applies DMARC can send to spam or refuse email that claims to come from your exact domain and fails the check. An example is a forgery of your own managing director's address sent to your staff or your customers. The receiving system always makes the final decision. DMARC does not deal with lookalike domains, or the display name shown beside an address. A record set to p=none expresses no preference about what happens to a forgery. DMARC has its own guide.
- 4The supplier's domain matters too. FourWinds checked 400 Irish small-business email domains on its own outreach list on 2 October 2026: 61% had no DMARC record, 32% had one set to p=none, and 7% enforced it. An email showing a supplier's real address is not proof the supplier sent it.
- 5Lookalike domains need their own control. The NCSC advises blocking incoming email from newly registered domains and from domains with small typos. FraudSMART's guide gives a .com address, where the supplier uses .ie, as the kind of change to look for.
What the law requires, and what it does not
The call-back and the second approver are advice from the NCSC, An Garda Síochána and FraudSMART, and none of the three cites a law that requires either. Firms regulated by the Central Bank should check their own sector rules. Verification of Payee is a duty on banks. For single payments, your business has nothing to register for or switch on.
If a bank fails to run the check and the payment goes wrong as a result (a defectively executed payment), your bank must refund the amount without delay (Article 5c(8)). Any further financial loss may be compensated under the law that applies to your contract with the bank.
The GDPR comes in where personal data is at risk. It requires you to have technical and organisational security measures that match the risk (Article 32), and that includes a mailbox holding customers' and staff's details. A forged email that persuades somebody to pay, with nobody inside your systems, is a fraud. Where the attacker got into a mailbox or system holding personal data, that unauthorised access is also a personal data breach (Article 4(12)). Articles 33 and 34 then decide whether the DPC and the people affected have to be told.
One Irish law bears on reporting to the Gardaí. Under section 19 of the Criminal Justice Act 2011, it is an offence to fail, without reasonable excuse, to tell a member of the Garda Síochána, as soon as it is practicable, information you know or believe might be of material assistance. That means material assistance in preventing somebody else committing a relevant offence, or in securing the arrest, prosecution or conviction of somebody else for one. In the District Court (summary conviction) the penalty is a class A fine, up to 12 months in prison, or both. On indictment it is a fine, up to five years in prison, or both. The relevant offences in Schedule 1 include theft (section 4), making a gain or causing a loss by deception (section 6) and unlawful use of a computer (section 9) under the Criminal Justice (Theft and Fraud Offences) Act 2001, and conspiracy to defraud. An Garda Síochána's fraud page cites section 19 as a legal obligation to report information about possible frauds to your local Garda station, which is the report advised above.
A new EU Payment Services Regulation is coming and is not law yet. Parliament and Council negotiators reached a provisional deal on 27 November 2025. Parliament's release describes a duty on banks to check that a payee's name and account identifier match, and makes banks liable if they fail to put fraud prevention in place. The refund it describes for impersonation fraud covers a criminal posing as the bank's own staff, not a supplier. As at 15 October 2026 the European Parliament's Legislative Observatory lists the Regulation as awaiting the Council's first-reading position. It has not been adopted, it has no date of application, and nothing in it applies yet.
A contract can add duties the law does not. Where a larger customer or an insurer has sent questions about your security, the NIS2 supplier questions and the cyber insurance questionnaire have their own guides.
The Irish figures, and the samples behind them
FraudSMART reported on 27 March 2026 that Irish SMEs lost almost €19 million (€18.9 million) to email-related scams over the past two years. Its members saw average losses of over €22,000 per incident, and it said the majority of cases were invoice redirection, with CEO impersonation less common. The release does not name the two calendar years.
An earlier release, on 10 April 2025, gave a split: of €17.4 million lost between January 2023 and December 2024, €15.7 million was invoice redirection and €1.7 million was CEO impersonation. The two periods overlap, so the totals cannot be added together.
The 2026 release also reports a survey FraudSMART ran with ISME members in February and March 2026, with 65 responses. 67% said they had been targeted by a financial scam in the last 12 months and 78% had received an unexpected or urgent request that raised suspicion; of those, 80% said they had checked it independently. 53% said they did not have fraud awareness guidelines and training in place for employees. The release gives the channels as email (88.4%), phone calls (51.2%) and text messages (48.8%). The three add up to more than 100%, and the release does not say what each figure is a percentage of. Sixty-five responses from members of one business association is a small sample, and the percentages are an indication, not a measurement of Irish SMEs.
The NCSC's guidance of 25 July 2025 says that in 2023 SMEs alone lost almost €10 million to invoice redirect fraud. An Garda Síochána lists invoice redirection fraud and CEO fraud among the six most common types of fraud in Ireland, and its page gives no loss figures for either.
Sources
- 1.Fraud: the six most common types, and how to report · An Garda Síochána
- 2.Almost €19 million lost by SMEs to email-related scams over the past two years, 27 March 2026 · FraudSMART, Banking & Payments Federation Ireland
- 3.Protecting Against Business Email Compromise and Payment Fraud, 25 July 2025 · National Cyber Security Centre
- 4.Protect Your Business from Fraud · FraudSMART, Banking & Payments Federation Ireland
- 5.Verification of Payee (VOP) · Banking & Payments Federation Ireland
- 6.Regulation (EU) 2024/886, the Instant Payments Regulation: recital 20 and Articles 5b(2) and 5c · Publications Office of the European Union
- 7.Additional VOP information for businesses · Banking & Payments Federation Ireland
- 8.S.I. No. 6 of 2018, the European Union (Payment Services) Regulations 2018, Regulation 111 · Irish Statute Book, Office of the Attorney General
- 9.Regulation (EU) 2016/679, Articles 4(12), 32, 33 and 34 · Publications Office of the European Union
- 10.Directive (EU) 2015/2366, the second Payment Services Directive, Article 88 · Publications Office of the European Union
- 11.Regulation (EU) No 260/2012, the SEPA Regulation, Article 1 · Publications Office of the European Union
- 12.Second level school a victim of a whale phishing attack · Data Protection Commission
- 13.RFC 9989, Domain-Based Message Authentication, Reporting, and Conformance (DMARC) · Internet Engineering Task Force
- 14.Criminal Justice Act 2011, as revised, sections 3 and 19 and Schedule 1 · Law Reform Commission
- 15.Criminal Justice (Theft and Fraud Offences) Act 2001, as revised, sections 4, 6 and 9 · Law Reform Commission
- 16.Payment services deal: more protection from online fraud and hidden fees, 27 November 2025 · European Parliament
- 17.Procedure file 2023/0210(COD), the Payment Services Regulation · European Parliament, Legislative Observatory
- 18.Over €17 million lost by SMEs through email-related scams in the last two years, 10 April 2025 · FraudSMART, Banking & Payments Federation Ireland
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Oscar Cobbe · Founder, FourWinds Digital
Writes and maintains the legal explainers on this site, and does the compliance work behind them. Every date and article number here is checked against the legislation itself before it is published, and updated when the law changes.
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Written on 15 October 2026 and accurate as at that date. This is general information about how the rules work, not legal advice on your situation. Where you need a solicitor, we say so.