The cost of time: Why manual dispute processes can't meet PSD2 deadlines

Fraud & Disputes
Dec 16, 2025

Let's talk about a problem that's probably keeping your compliance team up at night.

PSD2’s refund mandate is clear: for unauthorised payments, the payer must be refunded immediately, and no later than the end of the next business day.

Except when your dispute process relies on manual work for every single case, those hours disappear fast. When fraud spikes (exactly when you need your process to work), everything falls apart.

Where the clock runs out

Here's what actually happens when a cardholder reports fraud:

The front office scrambles. Your case handler needs to collect information, validate the claim, and start the internal process. Even for obvious fraud cases, this eats into your already tight window. Every minute spent on data entry brings you one minute closer to missing that deadline.

The back office gets stuck. Once the case finally reaches dispute teams, they're manually entering data again, classifying transactions, and deciding whether to file a chargeback or try pre-dispute resolution. This is rational, repetitive work that honestly shouldn't need much manual work.

The compliance risk hits. Miss that next-business-day deadline? You're looking at regulatory breaches, potential scrutiny, and customers won’t trust you with their primary card again. Losing top-of-wallet status has real financial consequences.

This is repetitive, rules-based work that adds little value and consumes critical time within the PSD2 window.

The leaky bucket problem

A lot of banks think they've solved this by adding a digital form to the front of their manual process. That's like putting a shiny new tap on a rusty, leaking bucket. Sure, the intake isn’t digital, but you might still be missing relevant data and information to analyse and come to a decision about the case.

From a regulatory perspective, cosmetic improvements at intake do not address the underlying risk of missed refund deadlines. You need a unified process and automated system that moves cases from intake to resolution without constant human intervention.

What zero-touch recovery actually looks like

Zero-touch recovery means resolving disputes and crediting cardholders without manual handling for standard, low-risk cases, all while maintaining appropriate oversight and controls. This is usually achieved via automation and collaboration with merchants via platforms like Ethoca and Verifi.

For issuers, automation is not about speed alone; it is about ensuring consistent, provable compliance with regulatory timelines.

Our dispute management solution, Amiko, makes this happen through three connected pieces:

Smart intake that actually understands compliance

Amiko's virtual agent doesn't just collect information from the cardholder. It guides cardholders through a compliant process built on Visa and Mastercard dispute rules and frameworks. For straightforward fraud cases, the system validates the claim instantly and sets the resolution path automatically. Your compliance clock starts ticking, and the system's already moving.

Direct lines to merchants

Instead of immediately filing chargebacks, Amiko connects with merchant collaboration platforms like Ethoca and Verifi. These networks are widely used across the card ecosystem to enable faster merchant responses and reduce unnecessary chargebacks.

The goal? Get a direct merchant credit to the cardholder within the PSD2 timeline, before you even need a formal dispute. This dramatically speeds up refunds for the majority of cases and keeps everyone happy.

Actually automated crediting

When you combine intelligent intake with merchant collaboration, you get real zero-touch recovery. While results vary by portfolio composition, merchant mix, and dispute strategy, the numbers we see paint a clear picture:

  • About 35% of disputes across entire portfolios get zero-touch recovery (through merchant collaboration).
  • 66% of all refund responses from merchants happen within 24 hours, so your team can focus on cases where merchant collaboration was not successful.
  • The system works 24/7 (evenings, weekends, and holidays), even when your team is not.

That last point matters. Fraud doesn't take weekends off, but your manual process does. Automation ensures compliance continuity across time zones, weekends, and fraud spikes.

Building your own competence for critical processes

A common challenge among large issuers is dependency on fragmented third-party suppliers for critical dispute workflows.

Moving to a unified, automated platform like Amiko helps you build internal competence. When you automate the routine dispute cases, your dispute agents can focus on genuinely complex cases. You're processing faster and building a stronger operation overall.

Banks such as Cembra, for example, are already seeing these benefits, and the competitive advantage is real. While competitors struggle with manual backlogs, automated systems handle surges without breaking a sweat.

The real cost of staying manual

Manual dispute processing comes with real, compounding costs:

  • Regulatory breaches for missed refund deadlines.
  • Erosion of customer trust due to delayed support or credits.
  • Operational overload during fraud spikes.
  • Loss of Top-of-wallet status.
  • Dispute team burnout from repetitive, time-critical work.

The question is worth asking: Can you afford not to automate?

What happens next

PSD2 timelines are not becoming more flexible, and fraud volumes are not slowing down. Issuers that continue to rely on manual dispute handling are taking an increasing compliance and operational risk.

Across the industry, payment operations are increasingly being redesigned around automation as a baseline requirement.

Amiko, Rivero’s dispute management platform, helps issuers meet PSD2 refund deadlines through automated intake, merchant collaboration, and zero-touch recovery and resolution while preserving control for complex disputes. Its infrastructure is designed for regulatory reality, not best-case assumptions.

If you’re ready to replace manual bottlenecks with a dispute process built for speed and compliance, learn more about Amiko at https://rivero.tech/amiko.