Even a Late Card Loss Report Is Covered for the Previous 60 Days — Article 16 and the Six Exceptions That Shift the Loss to You

Where the 60-day figure comes from

The basis is Article 16 of the Specialized Credit Finance Business Act. It splits into two clauses.

• Clause 1 — the issuer bears responsibility for use of the card from the time it receives notice of theft or loss from the member.
• Clause 2 — for use arising before that notice, the issuer bears responsibility within the range of the 60 days preceding the date the notice was received.

In practice that means the following. If you report a loss on 16 August, fraudulent third-party charges dated on or after 17 June fall within the scope of the compensation review. Reporting late does not by itself push the entire amount onto you.

Read the other way, anything older than 60 days is not recovered under this provision. That is where people genuinely lose money: cards that sit unused for long stretches, or statements nobody reads. If you carry several cards, simply switching on payment alerts sharply raises the odds of catching something inside that 60-day window.

So when do you report — before you are certain

The most common mistake is "let me look for it a bit longer, then report it." Even with the 60-day reach-back, everything after the report is entirely the issuer's responsibility, so reporting sooner shrinks the disputable territory itself. Card apps now let you place a card on temporary hold and lift it if the card turns up. When a reversible option exists without reissuing, there is no reason to delay.

If your phone went missing along with the card, one more step comes first: telecoms and authentication before cards. The order of operations for that case is set out in what to do in the first 30 minutes after losing your phone.

The six situations where the 60 days does not apply

This is where cases actually divide. Article 40(3) of the Standard Terms for Individual Credit Card Members enumerates the circumstances in which an issuer may place all or part of the responsibility on the member.

• ① Fraudulent use resulting from the member's intent
• ② Fraudulent use arising from a card that was never signed
• ③ Where the member disclosed the PIN intentionally or negligently (disclosure under violence or threat to life excluded)
• ④ Where the card was transferred to another person or pledged as security — family and cohabitants included
• ⑤ Where the member negligently left the card exposed or unattended
• ⑥ Where the member deliberately delayed reporting without reasonable cause

The two that catch people most often in ordinary life are ③ and ④: a PIN written on the back of the card or on a note in the wallet, or a card handed to a spouse or child to use. Item ④ in particular names family explicitly. "It is family, so it should be fine" does not work here, and because a family card is a separate product in its own right, it should be distinguished from lending a card out.

Why PIN-based transactions are hard to dispute

Cash advances, some ATM transactions and payments requiring PIN entry all leave one fact on the record: whoever did this knew the PIN. For the issuer that is grounds to treat the case as falling under ③; for the member it turns into an obligation to argue that no disclosure occurred. The position is materially worse than for a signature transaction.

The practical defence is therefore simple. Do not keep the PIN with the card, the wallet or a note on the phone, and do not use a number that can be inferred from the ID sitting in the same wallet, such as a birth date or phone number. If you are worried about account security more broadly, it is worth reviewing how to check whether your data has been leaked at the same time.

How the compensation process runs

Once the report is filed the issuer investigates whether the use was fraudulent. The member explains that they did not make the charges, and the issuer decides on the basis of merchant sales slips, signatures, the time and place of payment and requests for CCTV review. A police report receipt is frequently required at this stage, so if theft is suspected it is worth filing with the police alongside the card report.

For reference, using another person's card without authority is a punishable offence under Article 70 of the Specialized Credit Finance Business Act as fraudulent card use. Picking up a lost card and using it falls within this too.

When you disagree with the outcome

If the issuer concludes the loss is yours and you cannot accept that, the first move is to obtain in writing which subparagraph of Article 40(3) of the Standard Terms the decision rests on. If the provision is not identified, neither is the point you would be disputing. The step after that is the Financial Supervisory Service's complaints line (1332) and its dispute mediation process.

How difficult it is to recover money once it has left is much the same in other contexts. Why freezing an account is rarely as simple as it sounds is covered in secondhand trading fraud and payment freezes.

In short

• ① If loss or theft is suspected, place a hold before you are sure. You can lift it if the card turns up
• ② Compensation reaches back to 60 days before the report date (Article 16(2))
• ③ PIN disclosure, transfer to another person including family, an unsigned card and deliberate delay shift the loss to you
• ④ Where theft is suspected, secure a police report receipt as well
• ⑤ Payment alerts raise the chance of spotting it inside the 60 days
• ⑥ If you disagree with the outcome, get the governing provision in writing, then contact the FSS on 1332

A credit card is both a payment instrument and a record within your credit file. A disputed fraudulent charge that goes unresolved and slips into arrears becomes a separate problem, so it is worth monitoring the billing status even while an investigation is running. What credit scores actually respond to is set out in how a credit score is built.

This article was compiled in August 2026 from Article 16 of the Specialized Credit Finance Business Act (liability for fraudulent use of credit cards), Articles 15 and 70 of the same Act, Article 40(3) of the Standard Terms for Individual Credit Card Members, and the Ministry of Government Legislation's Easy Law guide on unlawful credit card use. Whether and how much is compensated depends on the issuer's investigation and the individual terms of your contract, so treat the terms and guidance of your own card issuer as the operative source. This article is procedural guidance and does not substitute for legal advice.