Why FilmPass Paused Trading on 23 December 2024 and Has Not Yet Resumed

Last updated: 27 December 2025

Purpose of this message

This message explains why FilmPass Ltd paused all trading on 23 December 2024 and has not resumed trading since.

This decision was not caused by financial failure, liquidity issues, or operational collapse.
It was a deliberate and proportionate governance and risk-control decision, taken to protect members, customers, and the business while unresolved structural questions were investigated.

What FilmPass provides

FilmPass operates as a reseller of Multi-Use cinema ticket eVoucher Codes.

Members purchase digital codes which can later be redeemed at participating cinemas.
Value is therefore realised at redemption, not at the point of purchase, often weeks or months later.

This model depends on:

clear merchant identity,
transparent system behaviour,
predictable redemption, and
confidence that the surrounding infrastructure operates neutrally and explainably.

What triggered the pause (December 2024)

By late 2024, FilmPass identified persistent and unexplained patterns affecting both its business and its members.

These included:

card statements showing merchant identities that did not clearly match the website where a purchase was made,
repeated difficulty explaining transactions, refunds, or disputes to customers,
responsibility being passed between merchants, intermediaries, and payment infrastructure without any party able to explain the full journey.

At the same time, disclosures obtained only after prolonged escalation confirmed that:

behavioural data was being generated not only when purchases were made, but when websites were visited, including session behaviour, timing, device consistency, and follow-through;
this data was processed within a shared ecosystem combining commerce infrastructure, trust and reassurance layers, payment processing, and fraud-prevention systems;
the outputs of that system (such as confidence, reliability, or risk outcomes) were visible to some participants in the ecosystem, but not to FilmPass;
FilmPass and its members were not told that this behavioural insight existed, how long it persisted, or how it might influence outcomes elsewhere.

The core issue (in plain terms)

The issue was asymmetry.

FilmPass operated as a voucher reseller without access to behavioural insight, while other ecosystem participants accumulated and acted upon behavioural signals generated by shared commerce, trust, payment, and fraud-prevention infrastructure.

This meant that some participants could:

observe browsing and abandonment,
infer demand and intent,
anticipate redemption behaviour, and
adapt their own offers or controls,

while FilmPass could not see, verify, or mitigate any of this.

This was not disclosed to FilmPass.
It was not visible to FilmPass.
It was not something FilmPass could responsibly explain to members.
Nor was it information FilmPass could access or verify in its role as a business customer, where activity involving individual members is processed in a separate personal capacity downstream.

FilmPass competed on:

price,
inventory, and
customer trust.

Other participants in the cinema ticket ecosystem operated as legally separate entities, often representing competing brands and competing cinema chains, while being connected operationally through shared payment and commerce infrastructure.

That structure meant behavioural insight generated in one commercial context could exist within the same underlying infrastructure as insight generated in another, even where the consumer-facing businesses were competitors.

FilmPass did not have visibility into how those connections were structured, how insight flowed between them, or how signals generated in one context might influence outcomes in another. FilmPass was also not in a position to verify or interrogate those arrangements.

As a result:

FilmPass operated as a voucher reseller without access to behavioural insight, while other ecosystem participants accumulated and acted upon behavioural signals generated by shared payment and fraud infrastructure. That asymmetry distorted competition by allowing some participants to anticipate, segment, and influence voucher demand in ways FilmPass could not see, match, or mitigate.

This created an uneven playing field that FilmPass could not responsibly operate within.

Why FilmPass directed refunds via banks (chargebacks)

When trading was paused, FilmPass advised members of their right to seek refunds via their bank if they wished.

This was a protective decision, not an avoidance of responsibility.

Refunds, reversals, and chargebacks do not end when a transaction ends.
They generate long-lived signals within payment and fraud-prevention systems that can affect:

individuals,
merchants,
SMEs, and
brands well beyond the original purchase.

At the time, FilmPass did not have sufficient visibility into how those downstream effects operated.

Banks and card issuers, as the independent and empowered dispute authority, have stronger investigative powers, clearer authority over disputes, and direct access to the relevant infrastructure.

Deferring to banks was therefore the most responsible option available.

Why the pause has continued (Dec 2024 – Dec 2025)

Since pausing trading:

FilmPass has not sold any new vouchers,
no revenue has been generated, and
no trading activity has resumed.

The pause remains in place because:

the structural questions identified have not yet been resolved,
explanations received to date remain partial and fragmented, and
no single organisation has yet been able to explain the system end-to-end.

This is not just about FilmPass.

Why this matters for members and past redemptions

FilmPass has a duty not only to itself, but to every member who purchased and redeemed Multi-Use cinema ticket eVoucher Codes, as well as members who simply visited or browsed our platform and did not complete a purchase.

Within modern commerce systems, behavioural signals can be generated by website visits alone, including session activity, navigation patterns, device consistency, and timing, regardless of whether a transaction takes place.

FilmPass therefore needs to understand:

how redemption behaviour was observed,
what data was generated at redemption,
what data may have been generated through browsing or attempted checkout activity,
who could see or act on those signals, and
whether any member may have been treated differently as a result.

Without that clarity, FilmPass cannot responsibly resume trading or provide full assurances to its members.

Why this has taken over a year

This matter has taken time not because of inaction, but because meaningful resolution has not been possible through ordinary channels.

Throughout this period, FilmPass has sought explanation from:

merchants involved in the customer journey, and
the payment and infrastructure providers involved in processing.

Those parties have not yet been able to provide a complete, end-to-end explanation of how the combined systems operate or where responsibility sits across the full lifecycle.

Responsibility remains distributed.
Visibility remains fragmented.

FilmPass cannot resolve this unilaterally.

Summary

FilmPass paused trading on 23 December 2024 because:

a shared commerce, trust, payment, and fraud-prevention infrastructure created hidden behavioural insight about voucher buyers,
that insight was unequally distributed,
the resulting asymmetry distorted competition and transparency,
FilmPass could not honestly explain the system to its members, and
continuing to trade would have exposed customers to opaque risks.

The pause remains in place because those structural issues remain unresolved.

This was a protective decision, not a commercial failure.

We have described what happened and why it mattered.
We have not alleged intent, wrongdoing, or illegality.

Determining whether these structures are acceptable, compliant, or appropriate is not our role.

We remain committed to resolving this situation constructively and transparently, and we thank members for their patience.

The FilmPass Team