Financial Ombudsman Service decision

Prepay Technologies Ltd · DRN-5733513

Banking Services GeneralComplaint upheld
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The verbatim text of this Financial Ombudsman Service decision. Sourced directly from the FOS published decisions register. Consumer names are reduced to initials by FOS at point of publication. Not an AI summary, not a paraphrase — every word below is the original decision.

Full decision

The complaint Mr A complains about the difficulties he had trying to recover funds held in his Prepay Technologies Ltd prepaid travel card account. Mr A is unhappy with the service he received when he attempted to contact Prepay Technologies. He is also unhappy that his account balance was reduced as a result of Prepay Technologies applying inactivity fees. What happened In 2019, Mr A purchased a pre-paid single currency card from a shop. The card was issued by Prepay Technologies, but it appears that Mr A did not initially realise that Prepay Technologies had any involvement. He used the card for some purchases, but it then remained unused for a period with a balance held in the account. Mr A told us that he wanted to withdraw the remaining funds, but struggled to work out how to do so. He said he got in touch with the shop he originally bought the card from, as well as with Mastercard, but was unable to withdraw his money. Prepay Technologies told us that, in line with the terms set out in the user guide, it began to apply inactivity fees on the account on a monthly basis 12 months after the account was last used. The terms said that fees would not be charged if account balance was at zero or if the balance became too low for a fee to be charged. Prepay Technologies told us that it contacted its customers shortly after 8 June 2021 to make them aware that their single currency cards were being replaced by a multi-currency card. The notification that Prepay Technologies say they sent to all their customers explained the timeline for the closure of the single currency accounts, starting with the ceasing of the ability to reload the card, it would then no longer be possible to use the card for card transactions or at an ATM from 28 February 2022. The copy of the notification Prepay Technologies provided to us gives details of the steps that the account holder could take to recover funds held in their single currency card account before or after the deadline for the closure of the account. It also sets out that inactivity fees would be charged on balances held in the accounts subject to the terms and conditions. Mr A told us that he did not receive this notification. He said that when he returned to the shop he bought the card from, he was told that his account details could not be traced. His money seemed to have disappeared, and he did not understand why. He thought the account should contain around €400. Records show no activity on the account held by Mr A from the date that it was closed other than the application of monthly inactivity fees. Prepay Technologies has explained that its records show that there was phone call on Mr A’s behalf (but not from Mr A himself) from a shop regarding Mr A’s account in November 2023. The notes suggest the call related to a balance transfer, but it was not processed. Prepay Technology’s records do appear to show that incorrect advice was provided as the caller was told Mr A could continue to use the card, which was incorrect as from 28 February 2022 the card could no longer be used.

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Mr A complained to the shop he purchased the card from, and then ultimately to the Financial Ombudsman Service. We explained that Prepay Technologies provided the card, and it offered to pay him £100 to apologise for poor customer service. Our investigator thought that offer was fair, but Mr A did not agree. The complaint was therefore referred to me. My provisional decision I issued a provisional decision in February 2026. I said: “I’ve considered all the available evidence and arguments to decide what’s fair and reasonable in the circumstances of this complaint. Firstly, I want to say that our investigator was right to look at Mr A’s complaint as a complaint against Prepay Technologies. Although Mr A bought the card from a shop, that shop is not responsible for the card or for any fees deducted. The responsibility for the card lies with Prepay Technologies. I think there are two reasons why the staff Mr A approached in the shop were not able to find his balance. The first is that by the time he spoke to them in November 2023, Prepay Technologies had already closed his account. That means the card was no longer attached to an account, and there was no account for the shop staff to access. The second reason is that the balance of Mr A’s card had decreased substantially as a result of inactivity fees. Prepay Technologies began charging a fee of €3 per month after 12 months of inactivity on the account. Prepay Technologies told us that as at 11 July 2025 the balance on Mr A’s account was €31.77. In principle, I think it was fair for Prepay Technologies to apply its terms and conditions to Mr A’s account. That means I don’t intend to order it to refund all of the inactivity fees that it charged. However, I do have concerns about the inactivity fees that were charged after Mr A should have been informed that his account was due to close. Mr A told us that he was not made aware of the impending closure of his single currency account, and he did not know how he could reclaim the funds in the account. Prepay Technologies told us it is confident it wrote to Mr A, in the same way that it wrote to its other customers, but it has not been able to provide records that show Mr A was contacted. In particular, it has not been able to tell us the address that it wrote to, nor has it been able to show the date of its correspondence. I recognise that Prepay Technologies has explained that their records are not complete as some internal records would have been lost through data retention procedures. But without supporting evidence to show that Prepay Technologies wrote to Mr A, I must consider what I think is likely to have happened based on the evidence I do have. On balance, I am not persuaded that Prepay Technologies did send notification of the account closure to Mr A’s correct address, nor am I persuaded that Mr A knew his account was due to be closed. From what I have seen I believe that had Mr A been made aware that his account was being closed earlier he would have taken steps in line with the guidance included in the notice. That means he would have retrieved the funds in his account before the deadline, and no further inactivity fees

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would have been charged. He would also have known that Prepay Technologies was responsible for this issue, and he would not have had to approach staff in the shop. My opinion is that, if everything had happened as it should, Mr A would have closed his account shortly after June 2021. I therefore intend to order Prepay Technologies to put Mr A in the position he would have been in if his account had been closed on 31 July 2021. I think [Prepay] Technologies should also pay interest on that amount, to reflect the fact that Mr A has been deprived of his funds. I also consider that Prepay Technologies caused Mr A to suffer avoidable distress and inconvenience. I say that because I am not satisfied that it gave him proper notice of the closure of his account, as well as because it wrongly told him (via the shop) that his account could still be used in November 2023. Prepay Technologies should therefore: • Pay Mr A the sterling equivalent of the amount held on his card as at 31 July 2021. • Add interest to that amount, at a rate of 8% per year simple, calculated from 31 July 2021 until the date of settlement. • Pay Mr A £100 for distress and inconvenience. Given the provisional findings I have made above, there is no need for me to comment on whether it was fair for Prepay Technologies to continue to charge an inactivity fee after Mr A’s account had been closed.” Mr A accepted my provisional decision, but PrePay Technologies did not. It provided a detailed reply, which I confirm I have considered in full. What I’ve decided – and why I’ve considered all the available evidence and arguments to decide what’s fair and reasonable in the circumstances of this complaint. While I have carefully considered all the evidence and arguments presented by both parties I have focussed my decision on the matters which I consider central to this complaint. Having done so, I have reached the same conclusions as I did in my provisional decision, for broadly the same reasons. But I will make some additional comments below. In my view, the key event here was the closure of Mr A’s account. I’ve noted Prepay Technologies’ further comments, but I am still not persuaded that Mr A was correctly notified of that closure. Prepay Technologies has said that Mr A would have been notified, but it has not been able to provide evidence to support its comments. I have noted PrePay Technologies’ explanation about why it cannot provide that supporting evidence, but nevertheless no supporting evidence exists. Mr A is adamant that he did not receive notification of the closure. It is of course possible that he has simply forgotten. But as I explained in my provisional decision, I think his actions (both at the time of the closure and subsequently) suggest that he did not have actual knowledge of the closure. In cases like this, where the evidence is incomplete or contradictory, I will base my decision on the balance of probabilities – in other words, on what I consider is most likely to have happened in the light of the evidence. Here, on balance, I am not persuaded that PrePay

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Technologies contacted Mr A in 2021 or 2022 to let him know about the imminent closure of his account. I stress that my findings here relate to the individual dispute in front of me. I make no findings about anything that may have happened to any of PrePay Technologies’ other customers (and indeed I have no power to make any such findings). I have ordered PrePay Technologies to pay compensation to pay compensation to Mr A, but I have not (and cannot) order it to pay compensation to any other party. PrePay Technologies has suggested that it is unfair for me to order it to refund the inactivity fees of €3 a month that were charged between 31 July 2021 and the account closure at the end of February 2022. I acknowledge that Mr A’s account was in fact open over that period, and that there was no activity on the account. But I think that if everything had happened as it should, Mr A would have known about the impending closure in June or July 2021 and he would have closed his account shortly afterwards. In that case he would not have paid inactivity fees between 31 July 2022 and 28 February 2022, and so I think it is fair for those fees to be refunded. PrePay Technologies has also said that the shop Mr A visited in November 2023 should have been able to find the balance of his account. By that point Mr A’s card could not be used, but PrePay Technologies says there is no reason why the shop staff could not have provided a balance. I did not realise that when I issued my provisional decision, and I apologise for my confusion on the point. But other than with respect to distress, I don’t think what happened in November 2023 makes a material difference here. If everything had happened as it should, Mr A’s account would have been closed well before November 2023. So, nothing that happened in the shop in November 2023 can have had any effect on Mr A’s financial loss. I also note PrePay Technologies’ comment that Mr A must have known how to access his money, because he fully set up his account when he opened it in 2019. But I don’t think that makes a material difference here. Regardless of whether Mr A could have seen his balance online, I still think PrePay Technologies should have proactively told Mr A in the summer of 2022 that his account was due to close – and for the reasons I’ve given, I’m not satisfied that it did that. Putting things right I remain satisfied that, if everything had happened as it should, Mr A would have closed his account shortly after June 2021. I therefore order Prepay Technologies to put Mr A in the position he would have been in if his account had been closed on 31 July 2021. Prepay Technologies should also pay interest on that amount, to reflect the fact that Mr A has been deprived of his funds. In addition to financial loss, I think the difficulties Mr A experienced here caused him some distress. I acknowledge that PrePay Technologies says there is no evidence of misinformation provided by the shop, but I note that it has previously provided us with a record showing that it told the store manager in November 2023 that Mr A’s card could still be used. At best, the record of the conversation between the store manager and PrePay Technologies suggests that the information given to the store manager was unclear – which suggests that the information given by the store manager to Mr A was also unclear. Having taken all the evidence into account, I remain satisfied that a payment of £100 is fair in respect of distress and inconvenience. Prepay Technologies should therefore:

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• Pay Mr A the sterling equivalent of the amount held on his card as at 31 July 2021. • Add interest to that amount, at a rate of 8% per year simple, calculated from 31 July 2021 until the date of settlement. • Pay Mr A £100 for distress and inconvenience. Given the findings I have made above, there is no need for me to comment on whether it was fair for Prepay Technologies to continue to charge an inactivity fee after Mr A’s account had been closed. My final decision I order Prepay Technologies Ltd to pay compensation to Mr A as set out above. Under the rules of the Financial Ombudsman Service, I’m required to ask Mr A to accept or reject my decision before 23 April 2026. Laura Colman Ombudsman

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