OSMP — how France collects payment fraud data

France runs a payment-fraud observatory with a statutory mandate, and its half-yearly and annual outputs are the benchmark your own fraud numbers get compared against. The Observatoire de la sécurité des moyens de paiement was created by Law 2016-1691 of 9 December 2016. It is chaired by the First Deputy Governor of the Banque de France, and among its statutory missions is to establish aggregated fraud statistics — which is what makes it a data-collection obligation for market participants and not merely a policy forum.

1. What it is, and who sits on it

The Observatory exists to facilitate the exchange of information and consultation between all parties concerned by the smooth functioning of payment means and the fight against fraud — consumers, retailers and companies, public authorities and administrations, and banks and managers of payment means.

Its composition reflects that: two parliamentarians, representatives of public administrations, payment market actors and users — merchants, businesses and consumers — and qualified individuals, under the chairmanship of the First Deputy Governor of the Banque de France.

2. The instruments it covers

The scope is broader than cards, and two entries in the list are the reason this matters to an e-money or remittance business:

• credit transfers;
• direct debits;
• payment cards;
• cheques;
• commercial paper;
• electronic money; and
• the transmission of funds.

3. What it publishes, and on what cadence

The Observatory draws up an annual report each year, which is sent to the minister responsible for the economy and submitted to Parliament. Alongside it, the Observatory publishes half-yearly key-figures notes on fraud statistics, which is the faster-moving output and the one most useful for benchmarking within a reporting year.

Two practical uses follow. First, the published aggregates give a market-level denominator against which a firm can sanity-check its own fraud rate by instrument — and a rate materially off the market is a question worth being able to answer before a supervisor asks it. Second, because the outputs are public and parliamentary, the definitions used are stable and citable, which makes them usable as an internal benchmark rather than as a one-off comparison.

The half-yearly cadence also has a governance use that is easy to overlook. A fraud committee that reviews internal numbers monthly and market numbers annually is comparing a moving series against a stale one. Aligning the internal benchmark review to the Observatory’s half-yearly publication gives the comparison a fixed cadence and a public reference point, which is a materially stronger position than an internal trend with no external anchor.

One caution on interpretation. Published market aggregates reflect the whole population of reporting participants, including business models very different from a specialist e-money or remittance firm. The right use is directional — is our rate on the same order, and moving in the same direction — rather than an expectation of convergence on the market average.

4. How it sits alongside the EU regime

The French collection does not replace the European one. A payment service provider operating in France remains subject to the EU-level fraud reporting framework built on the EBA guidelines under Article 96(6) of PSD2, whose taxonomy divides reportable fraud into unauthorised transactions and manipulation of the payer, and to the ECB payment statistics regulation.

Facts: an e-money institution operating in France maintains a single fraud dataset built around card chargeback reason codes.

What the analysis produces: that dataset can populate the card lines of the European taxonomy and little else. It cannot produce the credit-transfer and e-money lines, and it has no natural place for manipulation-of-the-payer cases, where the payer authenticated correctly.

What the practitioner does: restructures the fraud case record so the instrument and the fraud type are separate attributes captured at case creation, rather than derived later from a payment-scheme code. That single change is what allows one dataset to serve the EU statistical return, the EU fraud guidelines and the French collection without three parallel reconciliations.

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Related: PSD2 fraud reporting · The supervisory fraud taxonomy · The French reporting calendar