How to complain to First Direct
Banking complaints split into two families with very different rules. Payment problems, meaning unauthorised transactions, scams and failed transfers, sit under the Payment Services Regulations with tight statutory deadlines. Everything else, from account closures to lending decisions to service failures, sits under the FCA complaint rules and the Consumer Duty.
The rights that apply when you complain to First Direct
First Direct is a UK bank, so the rules below are the ones that decide your complaint. Each is named, because a letter that cites the specific rule is handled by a different team to one that does not.
- An unauthorised payment must be refunded by the end of the next business day after you report it, unless the bank has reasonable grounds to suspect you acted fraudulently. It cannot simply hold the refund while it investigates. Payment Services Regulations 2017, regulation 76
- It is for the bank to prove a payment was authorised, not for you to prove it was not. Use of your card or your credentials is not on its own proof. Payment Services Regulations 2017, regulation 75
- If you were tricked into sending money to a fraudster by bank transfer, you are entitled to reimbursement under the mandatory rules in force since 7 October 2024, unless you were grossly negligent. Payment Systems Regulator authorised push payment reimbursement requirement
- For anything you bought on a credit card costing more than £100 and not more than £30,000, the card issuer is jointly liable with the retailer for misrepresentation or breach of contract. You can claim from the bank instead of the retailer. Consumer Credit Act 1974, section 75
- A payment services complaint must get a final response within 15 business days, extendable to 35 only in exceptional circumstances. Other complaints get the standard eight weeks. FCA Handbook, DISP 1.6
First Direct complaints line: 0345 100 100 — put the complaint in writing as well. A phone call leaves no record you can rely on later.
The deadlines that decide your claim
Next business day — the unauthorised payment refund
Report an unauthorised transaction as soon as you spot it. The refund obligation bites by the end of the next business day, which is a far stronger position than waiting for an investigation to conclude.
13 months — the outer limit on unauthorised payments
You lose the right to a refund for an unauthorised payment if you do not notify the bank without undue delay and in any event within 13 months of the debit.
15 business days, or 8 weeks
Payment services complaints get a final response in 15 business days. Everything else gets eight weeks. Either clock expiring lets you go to the Financial Ombudsman.
6 months — the window to refer to the ombudsman
Six months from the final response letter to refer to the Financial Ombudsman. The letter must tell you this.
What to put in the letter to First Direct
Complaints teams work from a script. The detail below is what moves a case off that script and onto the desk of someone who can authorise a remedy.
- Whether you are complaining about a payment, which triggers the Payment Services Regulations, or about service or lending, which does not. Say which, because it sets the deadline the bank has to work to.
- The transaction dates, amounts and beneficiary details for every disputed payment.
- For a scam, exactly what you were told and by whom, and what the bank’s systems did or did not warn you about at the time.
- For a section 75 claim, the retailer, what was promised, what was delivered, and the fact that the purchase price was over £100.
- What you want: the refund, the interest, the credit file correction, and any distress and inconvenience.
If First Direct says no, or says nothing
Escalate to the Financial Ombudsman Service.
When you can go: After the final response, or after 15 business days for a payment services complaint, or eight weeks for anything else.
How long you have: Six months from the final response letter, and normally within six years of the event or three years from when you became aware of it.
What it costs: Free to you. The firm pays a case fee.
Whether it binds First Direct: Binding on the bank if you accept the decision.
Common questions
The bank says I authorised the payment because my card was used. Is that enough?
No. Regulation 75 of the Payment Services Regulations 2017 puts the burden on the bank to prove the payment was authenticated, accurately recorded and not affected by a technical breakdown, and it says explicitly that use of the payment instrument is not in itself necessarily sufficient to prove you authorised it or acted fraudulently or with gross negligence. Ask the bank to evidence the authentication and to explain, specifically, what it says you did wrong.
I was scammed into transferring money. Will I get it back?
Since 7 October 2024 there is a mandatory reimbursement requirement for authorised push payment fraud over Faster Payments and CHAPS. The sending bank must reimburse you unless it can show you acted with gross negligence, and there is a separate consumer standard of caution. Vulnerable customers are protected from that exception. Report it to the bank immediately, and to Action Fraud, and put the complaint in writing.
My bank closed my account with no explanation. Do I have any rights?
A bank can close an account by giving the notice in its terms, usually two months for a personal account, but it must act fairly and consistently with the Consumer Duty, and the notice period in the contract binds it. Where an account was closed immediately, ask for the contractual basis. The bank may be unable to tell you the reason if a suspicious activity report is involved, but the Financial Ombudsman can see the underlying material even where you cannot, which is why escalating is worthwhile here.
Can I use section 75 when the retailer has gone bust?
Yes, that is exactly what it is for. Section 75 of the Consumer Credit Act 1974 makes the credit card issuer jointly and severally liable with the retailer for misrepresentation or breach of contract on purchases over £100 and up to £30,000. The retailer being insolvent does not defeat the claim against the card issuer. If the card issuer refuses, take it to the Financial Ombudsman.
Where this comes from
Every rule on this page is drawn from primary legislation, a regulator, or an approved dispute resolution scheme. Check them yourself.
- Financial Ombudsman Service
- Payment Services Regulations 2017
- Consumer Credit Act 1974, section 75
- Payment Systems Regulator: APP fraud reimbursement
Paybacker is not a law firm and this is not legal advice. It is a summary of the published rules that apply to a bank, so that you can put your own case properly. For a dispute of real value, or anything turning on facts unique to you, speak to a solicitor or Citizens Advice.
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