Financial Services Merchant Accounts: Card Payments for Regulated and Specialist Firms
Published - 28 December 2017
Revised - 01 September 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.
Financial services businesses can face very different payment-processing requirements from conventional ecommerce or retail merchants.
But the term financial services merchant account can be misleading.
Financial services is not one merchant category, and payment providers do not assess every financial business in the same way.
A financial adviser taking a card payment for a professional advice fee presents a very different payment proposition from a business using cards to fund an investment account, transfer money, repay debt or purchase a financial instrument.
The first question should therefore not be:
“Which payment providers accept financial services?”
It should be:
“What exactly is the customer paying for, how does the money move, and which providers are willing and able to support that activity?”
This guide explains how merchant accounts work for financial services businesses, why some payment providers apply additional underwriting, how FCA status can affect an application and what firms should review before selecting a provider.
A financial services merchant account is a payment-processing arrangement used by a business operating within or alongside the financial-services sector to accept eligible card payments.
It is not necessarily a special type of bank account.
The phrase is generally used to describe merchant acquiring for businesses whose activities require additional consideration because of:
Depending on the provider, gateway and business, the merchant may be able to accept payments:
This is where financial-services payment applications often become much clearer.
Consider the difference between the following transactions.
| Example payment | What the card payment represents |
|---|---|
| Financial adviser fee | Payment for professional advice or services already provided |
| Insurance premium | Payment for an insurance product or policy |
| Claims-management fee | Payment for a claims-management service |
| Debt repayment | Money being used to repay an existing debt |
| Investment account funding | Money being transferred into an investment or trading environment |
| Money transfer | Funds being moved onwards to another beneficiary |
| Currency purchase | Money being exchanged into another currency or financial asset |
| Loan repayment | Money being used to repay borrowing |
| Membership or subscription | Recurring payment for access to a financial information or service product |
Although every example could broadly be described as “financial services”, they create very different payment flows.
Payment providers need to understand the purpose of the transaction, not simply the industry label.
This is particularly important where card funds are being used to fund, purchase, transfer or repay something financial rather than simply pay the merchant for a conventional service.
Being FCA authorised or regulated does not automatically mean every acquiring bank will support the business. Payment providers still apply their own merchant-underwriting and acceptance criteria. Our Payment Provider Risk Appetite guide explains the distinction between regulatory permission and provider acceptance.
Are Financial Services Businesses Considered High Risk?
Sometimes, but not automatically.
It is too simplistic to say that every financial-services business is high risk.
A provider may be comfortable with one regulated activity and unwilling to support another.
Current payment-provider policies illustrate this clearly.
For example, Adyen's current restricted and prohibited business list distinguishes between multiple types of financial activity. Some financial-service activities are marked as restricted and can require additional documentation, while other activities are prohibited under its policy.
See Adyen's current restricted and prohibited business policy.
Stripe likewise states that many financial services require additional review or may not be supportable, with categories including investment, lending, money transmission, currency exchange and other financial products subject to its current eligibility criteria.
See Stripe's current restricted-business guidance.
These are examples of provider policy rather than recommendations or a statement that every provider takes the same approach.
Provider appetite can change.
This is why a business should not assume:
“Provider X supports financial services.”
A more useful question is:
“Does Provider X currently support our precise activity, payment flow, jurisdiction and regulatory position?”
A merchant account does not authorise a business to conduct regulated financial activity.
Likewise, being authorised or registered with the Financial Conduct Authority does not automatically guarantee a merchant-account approval.
The FCA states that many financial-services activities require the business to be appropriately authorised or registered, and the Financial Services Register provides a public record of firms and individuals that are or have been authorised by the FCA or Prudential Regulation Authority.
Check the FCA Financial Services Register.
A payment provider may therefore ask:
The merchant should be able to explain its regulatory position accurately.
The payment provider's underwriting team is not a substitute for regulatory advice.
This distinction is particularly important for businesses moving or holding money on behalf of customers.
The FCA states that regulated payment services can include:
Read the FCA's guidance on the Payment Services Regulations and Electronic Money Regulations.
A business can therefore create an additional regulatory issue if it is not merely collecting money for its own goods or services but receiving customer money before passing it to another party.
The FCA specifically warns businesses such as marketplaces and booking platforms that receiving customer money before passing it onwards can potentially amount to providing a regulated payment service.
See the FCA's guidance on whether a business may be providing payment services.
Merchant acquiring and regulatory permissions should be reviewed separately.
A technically possible payment flow is not necessarily a regulatory permission to operate that flow.
Examples can include:
These examples should not be treated as one homogeneous provider category.
Provider suitability needs to be considered at individual business-model level.
Payment providers can have several reasons for carrying out additional underwriting.
The provider may need to establish that the business has the appropriate authorisation, registration or permissions where required.
The provider may distinguish between paying for a service and using a card to fund or purchase a financial product.
Financial-services transactions can sometimes involve significantly higher card values than conventional retail payments.
A customer may dispute a financial transaction after the underlying funds or financial benefit have already moved elsewhere.
Customer geography, card-issuer location and regulated activity across several jurisdictions can increase complexity.
The provider may need confidence in how the merchant identifies customers, manages fraud and complies with relevant financial-crime obligations.
Marketing claims, customer communications, cancellation rights and complaint patterns can also influence underwriting.
Sometimes there is no defect with the merchant at all.
The business may simply sit outside that provider's current risk appetite.
It can provide useful evidence about the business, but it should not be treated as automatic approval.
Where regulation applies, payment providers may view clear regulatory status positively because it helps establish:
However, the acquiring provider still carries out its own underwriting.
It may separately consider:
For businesses marketing regulated financial products or services to consumers, the website is more than a checkout.
It may also contain regulated financial promotions.
The FCA states that financial promotions should be fair, clear and not misleading.
Read the FCA's financial promotions guidance.
A payment underwriter may therefore review:
A payment provider approving a website does not mean the provider has approved the merchant's financial promotions for regulatory purposes.
Where the FCA's Consumer Duty applies, firms are expected to act to deliver good outcomes for retail customers.
The Duty came into force for open products and services in July 2023 and for relevant closed products and services in July 2024.
Read the FCA's Consumer Duty policy statement.
The relevance of the Duty depends on the firm, product and customer relationship.
It should not be assumed to apply identically to every financial-services merchant.
However, areas such as:
can also influence the overall quality of the merchant's payment and customer journey.
This distinction deserves particular attention.
A regulated adviser might charge £1,000 for advice that has been provided to a customer.
The card payment is payment to the merchant for its own service.
Another business might take £1,000 from the customer's credit card and use that amount to fund an investment, trading account, stored-value account or another financial position.
The money flow is fundamentally different.
The second transaction may create additional:
Do not submit a merchant-account application simply saying “financial services”. Explain exactly what the cardholder receives in exchange for the card transaction.
Average and maximum card values can materially change provider appetite.
Consider:
| Merchant | Typical payment |
|---|---|
| Advice subscription | £50 per month |
| Insurance broker | £600 annual premium |
| Professional adviser | £2,000 advice fee |
| Specialist financial service | £10,000 transaction |
| Investment-related payment | £25,000+ |
Even where the sector is acceptable, a provider may have:
Merchants should therefore disclose both average and maximum ticket values.
Recurring card payments can be useful for:
However, the provider needs to understand:
For the technical side, see our Subscription Payment Processing guide.
Not every financial transaction should automatically be accepted by card.
The business should consider:
Depending on the use case, alternatives can include:
The appropriate method depends on the underlying activity.
Some businesses may want to accept debit cards while restricting or avoiding credit-card payments.
Reasons can include:
This needs to be designed into the payment setup rather than assumed.
The merchant should confirm whether the proposed gateway and acquirer can support the required card-type controls.
Payment links can work particularly well where a financial-services firm:
The payment provider still needs to approve the underlying business and transaction type.
A payment link does not change the merchant's regulatory or underwriting profile.
Some financial-services businesses still collect payments over the telephone.
MOTO — mail order/telephone order — transactions can carry different authentication and fraud characteristics from standard ecommerce payments.
A provider may therefore want to understand:
The correct gateway depends on the payment journey.
Relevant capabilities can include:
However, gateway capability should follow provider eligibility.
A gateway can technically process a transaction while the acquiring provider remains unwilling to support the merchant.
For more on this distinction, see our Payment Gateways for High-Risk Merchants guide.
Cross-border financial activity can create additional complexity.
The business may need to consider:
A provider supporting a financial-services firm in the UK does not automatically mean that the same provider will support the business in every international market.
For broader cross-border payment considerations, see our International Merchant Accounts & Payments guide.
Multi-currency processing is a payment capability.
It does not determine whether a business is authorised to offer a financial product or service in another country.
A firm might technically be able to:
None of those capabilities automatically establishes whether the underlying financial service can legally be offered to the customer.
Payment architecture and regulatory market access should therefore be reviewed separately.
For the payment side of currency acceptance, see our Multi-Currency Merchant Accounts guide.
Requirements differ by provider and activity, but financial-services merchants should be prepared to explain the business in more detail than a conventional low-risk retail application.
| Area | Information that may be required |
|---|---|
| Business | Legal entity, ownership, trading history and business model |
| Regulation | FCA status, permissions, licence information or regulatory explanation where relevant |
| Product | Precise financial product or service supplied |
| Transaction purpose | Exactly what the customer receives for the card payment |
| Money flow | Where the funds go after payment |
| Volume | Monthly and annual card-processing volume |
| Ticket size | Average and maximum transaction values |
| Customers | Consumer/business split and customer countries |
| Processing history | Existing provider statements where available |
| Risk | Refunds, chargebacks, fraud and complaints |
| Website | URLs, regulatory disclosures, terms and customer journey |
| Payments | Online, MOTO, recurring, payment links or face-to-face |
| Financials | Accounts or other financial information where requested |
This can be one of the most useful things a financial-services merchant does before approaching a provider.
The payment provider may need to understand:
Customer → Merchant → What happens next?
For example:
Customer pays £1,000 → financial adviser receives £1,000 → payment settles as revenue for advice provided.
Customer pays £10,000 → money is transferred into an investment structure → financial asset or position is created.
Customer pays £1,000 → funds are passed onwards to another beneficiary.
Customer pays £500 → funds represent repayment of an outstanding debt → money may subsequently be distributed according to the commercial arrangement.
Those are not interchangeable payment risks.
The cleaner the money-flow explanation, the easier it is to identify which payment providers are genuinely relevant.
A decline does not necessarily mean the business cannot accept cards.
Possible reasons include:
If a business has already been declined, it is generally more useful to understand the likely reason before submitting applications to several other providers.
Our High-Risk Merchant Account Applications guide explains how businesses can prepare more complex applications.
Being regulated does not mean the merchant should submit a minimal payment application and expect automatic approval.
The provider may still need:
Regulatory status is one part of underwriting, not the entire application.
A payment provider will often review the merchant's website.
The site should make it reasonably clear:
If the website describes one business while the merchant-account application appears to describe another, underwriting can become unnecessarily difficult.
One provider may be perfectly adequate.
Multiple acquiring relationships can become relevant where there is a genuine requirement such as:
But adding providers creates additional:
It should therefore solve a defined problem.
For businesses considering this architecture, see our Acquirer-Agnostic Payment Gateways guide.
Start with providers that can genuinely support the activity.
Only then compare commercial terms.
Relevant costs may include:
A lower processing rate is not necessarily the best deal if the provider imposes materially worse settlement, reserve or operational terms.
For higher-volume businesses, see our High-Turnover Payment Fee Audit guide.
Not automatically.
A reserve is a provider-specific underwriting decision.
Potential factors include:
If a reserve is proposed, compare:
A provider comparison should go deeper than sector labels.
Ask:
This should happen before the merchant makes a formal application wherever possible.
Before comparing payment providers, we would normally break the requirement into six areas.
What is the firm's regulatory position and does the proposed payment activity fit it?
What exactly is the customer paying for?
Does the merchant keep the payment as revenue for its own service, or does some or all of the money move elsewhere?
Which providers currently have appetite for the activity, transaction values, customer geography and merchant profile?
Does the business need payment links, recurring billing, ecommerce checkout, MOTO, API integration or another payment structure?
What do processing, gateway, settlement, reserves, international charges and other terms cost in total?
For financial services, provider selection should follow the transaction rather than the industry label.
| Area | Information to prepare |
|---|---|
| Legal entity | Company name, registration and ownership |
| Regulatory status | FCA details, permissions or relevant regulatory explanation |
| Business model | Detailed description of the financial product/service |
| Transaction purpose | What the customer is paying for |
| Money flow | Where card funds go after settlement |
| Volumes | Monthly and annual card volume |
| Ticket | Average and maximum transaction values |
| Customers | B2B/B2C and customer countries |
| Processing | Current provider and processing history |
| Risk | Refunds, disputes, chargebacks and fraud |
| Technology | Website, gateway, API and integrations |
| Payment methods | Credit card, debit card, recurring, MOTO, links and others |
| International | Currencies, markets and settlement requirements |
Merchant Advice Service does not assume that every financial-services business requires the same payment provider.
We first try to understand:
From there, the aim is to identify payment-provider routes whose stated/current appetite may be relevant to the requirement.
MAS does not provide FCA authorisation, regulatory advice or payment-provider approval.
The selected provider completes its own underwriting, Know Your Customer and Know Your Business checks, risk assessment and final pricing.
For more about our process, see How Merchant Advice Service Works and How MAS Researches and Compares Payment Providers.
The FCA's public register of firms, individuals and other bodies that are or have been authorised or registered by the FCA or PRA.
FCA Financial Services Register
FCA guidance on regulated payment services, payment institutions and electronic-money businesses.
FCA payment-services regulation guidance
FCA guidance for businesses whose activities may involve receiving customer money and passing it onwards.
FCA guidance on providing payment services
FCA guidance covering promotions and advertising for regulated financial products and services.
FCA financial promotions guidance
FCA policy and guidance setting higher standards for relevant retail financial-services firms.
Current provider example demonstrating how individual financial-services activities can have different eligibility requirements.
Adyen restricted and prohibited products and services
Current provider guidance illustrating how some financial-services activities can require additional approval or be unsupported depending on the business.
Stripe restricted-business guidance
Merchant Advice Service is an independent payments information, comparison and provider-matching service.
MAS may receive commission or a referral fee from some payment providers where a business chooses to proceed following an introduction. This does not determine the factual information, provider-selection principles or regulatory information included in this guide.
Merchant Advice Service is not affiliated with the Financial Conduct Authority, Adyen or Stripe. Providers referenced in this article are used as examples of current provider policies and have not paid for inclusion.
Financial-services regulation depends on the precise activity, legal entity, jurisdiction, customer and business model. Merchant Advice Service does not determine whether a business requires FCA authorisation, registration or particular regulatory permissions.
A merchant-account approval does not constitute regulatory approval and does not give a business permission to conduct regulated financial activity.
Provider sector appetite, restricted-business policies, underwriting requirements, pricing, reserves, settlement terms and technical capabilities can change.
Merchant Advice Service does not make payment-provider underwriting decisions and cannot guarantee merchant-account acceptance.
Regulatory and provider information last checked: 26 August 2026
This guide provides general payment information and should not be treated as legal, regulatory, compliance, investment, financial or technical advice.
Written or reviewed by Libby James, founder of Merchant Advice Service and specialist in merchant payments and complex provider requirements.