High-Risk Merchant Accounts for Online Gambling Payment Processing
Published - 12 September 2024
Revised - 14 August 2026


Libby James is the founder and Managing Director of Merchant Advice Service. Since 2016, she has worked directly with businesses and payment providers across merchant accounts, card processing, payment gateways and complex provider requirements.
Libby specialises in high-risk, declined and harder-to-place merchants, as well as businesses requiring specialist payment methods, integrations or international support. She writes and reviews Merchant Advice Service content, drawing on practical experience gained from real merchant enquiries and provider relationships.
Online gambling businesses can face more specialist payment requirements because providers may assess licensing, operating jurisdictions, customer locations, transaction patterns and regulatory obligations before deciding whether to support the business.
Merchant Advice Service is an independent UK payments information and provider-matching service with experience researching payment requirements for regulated and higher-risk sectors, including online gambling.
Online gambling businesses normally need specialist payment processing.
An operator may have the correct gambling licence and a fully functioning platform but still struggle to find an acquiring bank, merchant account or payment gateway that supports its exact business model.
Providers will consider much more than whether they accept “gambling”. They will also examine:
The gambling activity being offered
The licences held
The countries in which players are located
The company receiving the settlements
Deposit and withdrawal arrangements
Previous processing history
Fraud and chargeback exposure
Responsible gambling controls
The currencies and payment methods required
This guide explains how online gambling payment processing works, what providers check during underwriting and why apparently similar gambling businesses can receive very different decisions.
Merchant Advice Service helps businesses understand which payment providers may be suitable for their activity, licence, target countries, transaction profile and technical requirements.
This may include operators that are:
Preparing to launch
Replacing an existing provider
Expanding into additional countries
Adding new payment methods
Looking for a second acquiring route
Experiencing declines or account restrictions
Connecting deposits and player withdrawals
Operating a complex or unusual gaming model
Approval is always subject to the provider’s underwriting and compliance checks. MAS does not guarantee acceptance or recommend that businesses apply to providers that have not knowingly approved their activity.
Online gambling payment processing allows an operator to accept deposits from players and, where supported, return funds or pay winnings.
A typical card-payment journey involves:
The player choosing a payment method
The payment gateway securely passing the transaction information
The acquiring bank submitting the payment through the card network
The player’s bank approving or declining the transaction
The funds being settled to the operator under the agreed terms
The merchant account receives card-payment settlements.
The payment gateway provides the technical connection between the operator’s website or app, its acquiring bank and any additional payment services.
Some operators also use payment orchestration to connect several acquiring banks, currencies and alternative payment methods through one technical integration.
Payment providers generally treat online gambling as a higher-risk or restricted merchant category.
This does not mean every gambling business is financially unstable or poorly operated. It means the provider expects increased regulatory, financial and reputational exposure.
This can be caused by:
Gambling licensing requirements
Fraud and chargeback risk
Cross-border transactions
Fast transaction volumes
Player deposits and withdrawals
Anti-money laundering obligations
Bonus and promotion complaints
Responsible gambling requirements
Card-scheme restrictions
Differences between international gambling laws
The possibility of licences or permissions changing
A gambling operator is therefore unlikely to be suitable for an ordinary ecommerce merchant account.
The acquiring bank or payment provider must knowingly approve the gambling activity, the licensed entity and the countries being served.
A gambling merchant account is an acquiring facility underwritten for betting, casino, bingo or another form of real-money gaming.
It enables the operator to receive settlements from card transactions through a provider that has approved the business model.
The application should accurately describe:
The type of gambling being offered
The operator’s licences
The countries being targeted
The company contracting with players
The company receiving settlements
Expected monthly processing volumes
Average and maximum deposit sizes
Player withdrawal arrangements
Accepted currencies
Marketing and affiliate activity
Previous merchant account history
Licensed gambling transactions are commonly associated with merchant category code 7995.
However, not every business using the word “gaming” is a gambling operator. Video gaming, esports, prize competitions and social gaming may be classified differently depending on how customers pay, participate and win.
A gaming payment gateway is the technical service that connects the operator’s platform to its payment providers.
Depending on the setup, it may support:
Debit card deposits
Open banking
Bank transfers
E-wallets
Prepaid payment methods
Mobile wallets
Local payment methods
Player withdrawals
Payment tokenisation
3D Secure
Fraud screening
Transaction reporting
Payment routing
Stored payment credentials
A payment gateway and a merchant account are not the same thing.
A gateway may provide the checkout and technical connection without providing the underlying acquiring facility.
Equally, an acquiring bank may approve an operator but require it to use a particular gateway or payment platform.
Before signing an agreement, operators should establish which company is responsible for:
The gateway
The merchant account
Card acquiring
Payment settlement
Player payouts
Fraud monitoring
Regulatory payment services
Customer support
The brand selling the solution may not always be the organisation providing the regulated payment service or acquiring account.
Specialist gambling payment processing may be required by:
Online casinos
Sports-betting platforms
Bingo operators
Poker sites
Lottery operators
Fantasy-sports businesses
Esports betting platforms
Social casinos involving real-money transactions
White-label gambling operators
Gambling software platforms handling payments
Payment facilitators supporting gaming businesses
Land-based gambling venues introducing digital payments
A provider that supports one type of gambling will not necessarily accept every operator in the sector.
For example, its appetite may differ between:
UK-licensed and offshore operators
Sports betting and online casino activity
Business-to-consumer and business-to-business platforms
Direct operators and white-label arrangements
Established companies and pre-launch businesses
UK players and international markets
This is why approaching a provider simply because it advertises “gaming payments” may still result in a decline.
A business providing remote gambling to consumers in Great Britain will normally need the appropriate Gambling Commission operating licence.
This can apply even where the operator is established outside Great Britain but makes gambling facilities available to British consumers.
The permissions required will depend on the activity and may include:
Remote casino
Remote bingo
Remote general betting
Remote betting intermediary
Remote pool betting
Remote lottery permissions
Payment providers will normally ask:
Which entity holds the licence?
Which brands and domains are covered?
Which countries are being targeted?
Does the licence permit those markets?
Is the applying company the licensed operator?
Which company contracts with players?
Is a white-label arrangement involved?
Where are the gambling equipment and payment entities located?
Are any markets served under separate licences?
A merchant account does not replace a gambling licence.
The payment provider must be satisfied that the operator can legally accept players in each relevant market.
Not every prize-based business is regulated gambling.
A properly structured free draw or genuine prize competition may operate without a Gambling Commission licence, provided it meets the relevant legal requirements.
For example, a genuine prize competition must involve a sufficient level of skill, knowledge or judgement.
A basic question that most participants can answer easily may not be enough to prevent the arrangement from being considered a lottery.
Even when a competition does not require a gambling licence, payment providers may still consider it restricted or higher risk.
The operator may be asked to provide:
A legal opinion
Competition terms
Details of the entry route
Information about free-entry methods
Prize-funding evidence
Draw procedures
Marketing materials
Previous processing history
Businesses should not describe themselves as “not gambling” without being able to explain and evidence the legal structure.
Available payment methods depend on the operator’s licence, target markets and acquiring arrangements.
Debit cards remain an important option for online gambling deposits.
The operator will need an acquiring bank that expressly supports gambling activity and the countries in which the cards are issued.
Open banking can allow customers to pay directly from their bank accounts.
It may provide an alternative to card deposits, but operators must still consider:
Player identification
Payment ownership
Affordability or financial-risk controls
Refunds
Withdrawals
Transaction monitoring
Source-of-funds checks
Some licensed e-wallets can be used for gambling transactions.
Operators serving British consumers must ensure an e-wallet is not being used to fund gambling using money originating from a credit card.
Prepaid cards and vouchers may be accepted in some circumstances.
The provider will consider whether the payment method is permitted, how the customer is identified and how the source of funds is monitored.
Apple Pay, Google Pay and similar wallets do not change the underlying card type.
A prohibited credit card does not become acceptable simply because it is stored inside a mobile wallet.
International gambling operators may need local bank transfers, wallets or alternative payment methods for different countries.
Payment-method coverage should be assessed market by market rather than assuming one checkout will work worldwide.
Businesses serving consumers in Great Britain must not accept credit card payments for gambling.
The restriction also covers credit-card-funded gambling payments made through an e-wallet or another money service.
Operators and payment providers therefore need controls capable of identifying the original funding source.
Removing credit-card branding from a checkout may not be sufficient if customers can still indirectly fund gambling using credit.
Underwriting requirements vary between providers, but gambling applications normally require more information than ordinary ecommerce applications.
These may include:
Certificate of incorporation
Ownership structure
Directors and ultimate beneficial owners
Registered and trading addresses
Group-company details
Business bank statements
Source-of-funds information
Financial forecasts
Evidence of operating capital
Providers may request:
Gambling licences
Licence numbers
Approved domains
Trading names
Markets covered by each licence
White-label agreements
Legal opinions
Regulatory correspondence
The operator may need to provide:
A live or test website
Customer terms and conditions
Privacy information
Responsible gambling content
Complaints procedures
Deposit and withdrawal terms
Bonus and promotion terms
Player-verification information
Customer-support details
Providers are likely to ask about:
Expected monthly turnover
Expected transaction numbers
Average and maximum deposits
Player countries
Accepted currencies
Deposit methods
Withdrawal methods
Refund and chargeback expectations
Historic processing statements
Previous payment providers
Existing reserves or retained balances
This may include:
KYC and age verification
Anti-money laundering policies
Sanctions screening
Politically exposed person checks
Fraud-monitoring procedures
Chargeback management
Responsible gambling controls
Affiliate monitoring
Source-of-funds checks
Customer-risk assessments
Applications are easier to assess when the business model, corporate structure and payment journey are clearly documented before they reach underwriting.
Gambling payment applications are rarely approved or declined because of one factor alone.
Providers normally assess the complete relationship between:
The activity
The licence
The operating company
The settlement company
Player geography
Transaction flow
Processing history
Payment methods
Fraud controls
Withdrawal arrangements
Finding a provider that accepts “gambling” is not enough.
The provider must accept the operator’s exact gambling activity, licence structure, target countries and transaction model.
Merchant Advice Service commonly sees problems where the business itself may be legitimate, but the application does not clearly connect these different elements.
For example:
The licence is held by one company but another company applies for the merchant account
The website is not ready for compliance review
Deposit processing has been considered but withdrawals have not
Player countries fall outside the provider’s permitted markets
The operator applies before its policies and procedures are complete
Previous payment history is not disclosed
A provider accepts gambling generally but not the specific licence or activity
The expected transaction volume does not match the provider’s appetite
The business cannot clearly explain the role of each company in the group
A well-prepared application should make the structure easy for an underwriter to understand.
A decline does not necessarily mean that no provider will accept the operator.
It may mean the application does not fit that particular provider’s:
Geographic coverage
Licence appetite
Transaction requirements
Risk policy
Technical setup
Minimum volume
Maximum exposure
Settlement arrangements
Common reasons for a decline include:
The operator does not hold the required licence
The licence does not cover the target market
The applicant is different from the licensed entity
The website is incomplete
The terms and payment information are unclear
Unsupported countries are being targeted
Processing history has not been disclosed
Chargeback or fraud levels are too high
The affiliate model creates additional risk
The operator cannot evidence its source of funds
The payment flow involves unsupported third parties
Withdrawal arrangements are unclear
The provider does not accept the particular gambling activity
The application has been submitted to the wrong type of provider
Submitting multiple applications without first understanding the reason for the decline can make the situation more difficult.
Before approaching another provider, establish:
Why the application was declined
Whether the issue can be corrected
Whether the provider’s appetite was unsuitable from the outset
Whether previous applications must be disclosed
Whether the business needs legal, licensing or compliance advice first
For gambling businesses, a payment solution should be considered as part of the wider operating model rather than as a standalone merchant account.
Merchant Advice Service recommends mapping the full requirement first: acquiring, gateway, jurisdictions, licences, currencies, alternative payment methods, fraud controls and any platform integrations.
That gives the business a clearer basis for identifying providers that understand the actual model and avoids treating every gambling merchant as though it has the same payment requirements.
MAS may be able to help you understand what providers are likely to examine before you submit another application.
This may be relevant where:
A merchant account is being terminated
Settlements have been delayed
A reserve has increased
The operator needs a replacement provider
A new market or licence is being added
A second acquiring route is required
The current provider does not support withdrawals or integrations
MAS cannot overturn a provider’s decision or remove a card-scheme restriction.
However, reviewing the business model, processing history and application requirements before approaching another provider can reduce unnecessary applications and identify issues that need to be resolved first.
There is no universal rate for gambling merchant accounts.
Pricing can depend on:
The licences held
Target countries
Monthly processing volume
Average transaction value
Card mix
Domestic and international transactions
Chargeback history
Fraud exposure
Settlement currencies
Reserve requirements
Length of processing history
Deposit and withdrawal methods
Possible costs include:
Acquiring margins
Monthly minimums
Setup or integration fees
Chargeback fees
Refund fees
Currency-conversion charges
Payout fees
Fraud-tool fees
Payment-orchestration charges
Operators should compare the full commercial proposal rather than focusing only on the headline percentage.
A lower transaction rate may provide poor value if it comes with:
Slow settlement
High payout fees
Large reserves
Low transaction limits
Restricted countries
Limited support
Unsuitable termination terms
A rolling reserve is a percentage of processed funds retained temporarily by the payment provider.
For example, the provider may hold an agreed proportion of each settlement for a set number of days or months.
The reserve is intended to cover potential:
Refunds
Chargebacks
Card-scheme assessments
Fraud losses
Other financial liabilities
Operators should confirm:
The reserve percentage
How long each amount is held
When funds are released
Whether there is a maximum reserve
Whether the reserve can be increased
What happens when the account closes
How long final balances can be retained
Reserve terms can have a significant effect on cash flow and should be reviewed alongside the processing price.
Settlement periods differ between providers.
Funds may be paid:
Daily
Several times a week
Weekly
Under another agreed schedule
New or higher-risk operators may initially receive slower settlement terms.
Settlement can be affected by:
Processing history
Chargeback levels
Fraud levels
Player countries
Currency
Reserve arrangements
Bank holidays
Acquirer reviews
Unusual transaction activity
Settlement to the operator is different from returning funds or paying winnings to an individual player.
Withdrawal arrangements should be planned before deposit processing goes live.
An operator may need:
Refunds to the original card
Card payouts
Bank-transfer withdrawals
Open-banking payouts
E-wallet withdrawals
Closed-loop payment controls
Manual review for higher-risk transactions
Operators should understand:
Which payment methods support withdrawals
Whether withdrawals must return to the original funding method
What happens when the original method is unavailable
How player identity is verified
When source-of-funds checks are completed
How withdrawal delays are communicated
How suspicious transactions are reviewed
Information that could reasonably have been requested earlier in the customer relationship should not be introduced only when a player asks to withdraw.
Unclear or unnecessarily difficult withdrawal procedures can lead to complaints, chargebacks and regulatory concerns.
Most remote gambling operators that hold customer funds must keep those funds separate from ordinary business funds.
Customer funds can include:
Unspent player deposits
Winnings left in player accounts
Certain crystallised bonuses
The customer-funds account is separate from the merchant acquiring arrangement.
Operators should understand:
Where player funds are held
Where card settlements are received
Which balances belong to customers
How withdrawals are funded
How reconciliation is completed
How customer-fund protection is explained
The acquiring bank, business bank and customer-funds bank may all be different organisations.
Fraud and chargeback controls should cover the full customer journey rather than only the point of payment.
Measures may include:
Age and identity verification
Payment-method ownership checks
Device analysis
Behavioural monitoring
3D Secure
Deposit limits
Transaction-velocity controls
Duplicate-account detection
Clear billing descriptors
Transparent bonus terms
Prompt customer support
Withdrawal monitoring
Affiliate oversight
Chargeback evidence storage
Monitoring by country and issuer
Operators should distinguish between:
Stolen-card fraud
Account takeover
Friendly fraud
Bonus abuse
Money laundering
Customer confusion
Service complaints
Unrecognised billing descriptors
Treating every dispute as the same type of fraud can prevent the operator from identifying the real cause.
For example, a high number of unrecognised transactions may be caused by a poor billing descriptor rather than deliberate fraud.
Mastercard’s Scam Merchant Monitoring Program becomes fully effective on 24 July 2026.
It creates a faster process for investigating activity that displays potential scam-related signals.
Licensed gambling does not automatically constitute scam activity.
However, gambling operators may experience transaction patterns that attract additional scrutiny, including:
High refund volumes
Customer disputes
Rapid transaction activity
Cross-border payments
Sudden changes in authorisation rates
Complaints involving promotions or withdrawals
For merchants within their first six months of Mastercard acceptance, one reported investigation trigger is a combined refund and chargeback rate above 5% during a rolling 30-day period, where at least 500 purchase transactions have been processed.
This means proactive refunds may still contribute towards that particular calculation.
Operators should not make legitimate refunds more difficult. Instead, they should reduce the reasons customers request refunds or contact their card issuer.
Useful controls include:
Clear promotion terms
Recognisable billing descriptors
Transparent withdrawal procedures
Accurate marketing
Prompt complaint handling
Organised transaction evidence
Monitoring refunds and chargebacks together
Where a scam-related investigation confirms scam activity, Mastercard acceptance may be stopped.
Operators should keep licensing, customer-service and transaction records accessible before an investigation occurs.
Several regulatory and card-scheme developments make it particularly important to review gambling payment arrangements during 2026.
The next phase of the Gambling Commission’s updated financial-limit requirements is due to take effect on 30 September 2026.
Operators will need to ensure their systems apply and communicate deposit limits in the required way.
Payment and platform systems should prevent customers from continuing to deposit after the applicable limit has been reached.
Since 19 January 2026, gambling operators must not apply wagering requirements exceeding ten times the value of bonus funds.
Clear separation between deposited funds and bonus funds is important for both the player journey and the handling of payment complaints.
Mastercard’s revised scam-monitoring standards shorten the period available to acquiring banks and payment facilitators when potential scam activity is identified.
Operators should ensure their providers understand the business model and can access relevant evidence quickly.
Regulatory and card-scheme requirements can change. Operators should confirm the current position with the Gambling Commission, their legal advisers and their payment providers.
Some established operators use more than one acquiring relationship or a payment-orchestration platform.
This may help with:
Supporting different countries
Accepting additional currencies
Improving approval rates
Reducing reliance on one provider
Separating licensed entities
Adding local payment methods
Operational resilience
Multiple acquiring routes must be transparent and properly underwritten.
They should not be used to:
Conceal chargebacks
Divide problematic transactions
Avoid monitoring thresholds
Disguise processing volumes
Bypass provider restrictions
Continue processing after a legitimate scheme termination
Each provider should understand the operator’s full business model and its role within the payment setup.
A second provider may reduce operational dependence on one relationship, but it cannot guarantee continued processing following a network-level restriction or confirmed scam finding.
Before signing an agreement, operators should ask:
Does the provider support our exact gambling activity?
Which licences does it accept?
Which player countries are permitted?
Which company will contract with us?
Who is the underlying acquiring bank?
Which payment methods are available?
Are deposits and withdrawals both supported?
Which currencies can be accepted and settled?
Is a rolling reserve required?
How long are funds held?
What are the settlement times?
What are the chargeback and refund fees?
Are there monthly minimums?
What transaction limits apply?
Can additional countries be added later?
Which fraud tools are included?
What happens if chargeback levels increase?
Can the account be terminated immediately?
How are retained funds handled after termination?
Does the solution support a second acquiring route?
What technical integrations are available?
Who provides support after the account goes live?
Commercial terms should be compared alongside underwriting appetite, market coverage and operational reliability.
First, establish why the facility has been closed or restricted.
Possible causes include:
Fraud alerts
Licensing concerns
Unsupported countries
Undisclosed business changes
Processing above agreed volumes
Card-scheme monitoring
Prohibited marketing
Changes in provider risk appetite
Regulatory concerns
Request written clarification where possible and collect:
Termination correspondence
Processing statements
Chargeback data
Fraud reports
Reserve information
Current licences
Updated website information
Evidence of corrective action
A new provider will normally want to know about the previous facility.
Failing to disclose a termination can lead to a later closure, even if the replacement account was initially approved.
Do not immediately submit multiple new applications without understanding the cause of the termination.
Merchant Advice Service provides independent guidance for businesses comparing merchant accounts, payment gateways and acquiring arrangements.
MAS may be able to assist with:
New gambling merchant account applications
Comparing potential payment routes
Complex licence or company structures
UK and international processing requirements
Declined applications
Replacement facilities following termination
Additional currencies or player markets
Payment gateway integrations
Deposit and withdrawal requirements
Secondary acquiring arrangements
Gaming models that do not fit a standard application
MAS does not approve applications, provide legal advice or conduct gambling licensing assessments.
The final decision is made by the acquiring bank or payment provider following its own underwriting and compliance checks.
Providing clear information at the beginning makes it easier to identify whether a suitable route may exist.
Include:
The type of gambling or gaming activity
The licences held
The company holding each licence
The countries in which players are located
Expected monthly card turnover
Average and maximum deposit
Required currencies
Whether the business is live or pre-launch
Current or previous processing history
Chargeback history, where available
Whether deposits, withdrawals or both are required
The platform or gateway being used
Details of any previous decline or termination
Sensitive documents do not normally need to be included in an initial enquiry unless they are specifically requested.
MAS will first review the basic business and payment requirements.
Where the enquiry appears suitable, this may involve:
Clarifying the activity, licence and target markets
Understanding the transaction and technical requirements
Identifying potential providers with a relevant appetite
Explaining the information likely to be required
Introducing the business to an appropriate provider where possible
MAS does not charge businesses for making an initial enquiry through the website.
Any provider terms, costs, reserves and settlement arrangements should be reviewed carefully before an agreement is signed.
This article provides general payment information and is not legal, licensing or regulatory advice. Requirements differ between countries and can change. Operators should confirm their position with the relevant regulator, legal adviser and payment providers.
Written or reviewed by Libby James, founder of Merchant Advice Service and specialist in merchant payments and complex provider requirements.