New UK regulations will change how merchant acquirers and certain payment facilitators report card sales information to HM Revenue & Customs (HMRC).
The Data-gathering (Ongoing Data: Interest and Payment Card Transactions) Regulations 2026 were laid before Parliament on 3 November 2026.
The regulations introduce ongoing reporting requirements, more frequent data submissions and additional obligations relating to merchant identification and information verification.
For payment providers, this creates operational requirements around data collection, reporting and compliance. For UK merchants, it may mean being asked to confirm information already associated with their merchant account.
Key Implementation Dates
1 March 2028
Regulations come into force
April 2028
First monthly card-sales reporting period
21 May 2028
First monthly return due
These dates relate to relevant merchant acquirers already operating when the new reporting regime begins. Different commencement rules apply to entities entering scope later.
What Are the New HMRC Card Sales Reporting Rules?
HMRC already receives card-sales information from certain acquiring organisations under existing information-gathering powers.
The new regulations modernise this process by moving to standing reporting obligations for in-scope organisations, rather than relying on individual information notices.
The main changes include:
- Monthly reporting of relevant card-sales data.
- Standardised electronic reporting requirements.
- Additional collection of merchant tax identifiers.
- Verification of information supplied by merchants.
- Advance notification to HMRC by in-scope providers.
- Record-keeping and due diligence requirements.
- Penalties for certain reporting and compliance failures.
HMRC intends to use more accurate and timely data to match card-sales activity with taxpayer records, improve tax administration and identify discrepancies requiring further investigation.
MAS Insight
This is principally a change to how payment providers report information to HMRC. It is not a new tax on card transactions and does not automatically create a separate monthly card-sales reporting obligation for every merchant.
Which Acquirers, Payment Facilitators and PSPs Are Affected?
The reporting requirements apply to organisations meeting the definition of a relevant merchant acquirer under the legislation.
Broadly, this includes qualifying merchant-acquiring businesses with the relevant UK corporation-tax connection. The legal definition and the activities undertaken by the entity determine whether it falls within scope.
Payment facilitators (PayFacs) may also be affected, depending on their operating model, contractual arrangements and role in settling card transactions.
However, not every organisation describing itself as a payment service provider, payment gateway or PayFac necessarily has the same reporting obligation.
| Payment Business | Reporting Consideration |
| Merchant Acquirer |
Directly relevant where the organisation meets the statutory definition and UK connection requirements. |
| Payment Facilitator |
May be in scope depending on the legal entity's activities, merchant relationship and settlement arrangements. |
| Payment Gateway |
Providing gateway technology alone does not automatically establish reporting responsibility. |
| Merchant / Retailer |
Generally provides relevant merchant information to its payment provider rather than making the acquirer's monthly return itself. |
Businesses wanting to understand these different roles can read our guides to payment facilitators and ISOs, PSPs and merchant acquirers.
What Information Will Acquirers Report to HMRC?
Schedule 4 of the regulations identifies the information relevant merchant acquirers must provide for reportable retailers.
The requirements apply to relevant retailers with a UK address to whom the acquirer has been contractually obliged to make settlement payments during the reporting month.
Merchant Identification
- Merchant name and address.
- Telephone number and email address.
- Relevant merchant and account identifiers.
- Trade classification identifiers, where allocated.
Tax Identification Information
- VAT registration number, where applicable.
- Company registration number for companies.
- National Insurance number, or the relevant confirmation, for individuals.
Card Transactions and Settlement
- Specified details of card transactions recorded against the merchant account during the month.
- The currency in which relevant transactions were made.
- Settlement account reference and branch information.
- Relevant acquiring identifiers.
The precise technical submission format is set out separately in HMRC's card sales data schema and associated guidance.
Importantly, the regulations concern payment-card data within their defined scope. They should not be interpreted as requiring every unrelated payment method to be reported under the same card-sales rules.
How Will the Rules Affect Merchant Onboarding and KYB?
One of the most important operational implications concerns the quality of information collected when a merchant account is opened.
Acquirers already undertake Know Your Business (KYB), Know Your Customer (KYC) and merchant underwriting checks.
The HMRC requirements add more specific obligations around collecting and verifying reportable tax identifiers and other information.
Under HMRC's published due diligence guidance, relevant providers are expected to:
- Verify the merchant information required under the reporting rules.
- Check company registration numbers against Companies House information.
- Use appropriate checks for VAT registration numbers.
- Check the format and reliability of National Insurance numbers where relevant.
- Investigate material discrepancies or unreliable information.
- Maintain records of the verification work undertaken.
These requirements could lead providers to update their application forms, onboarding systems, internal compliance procedures and merchant information records.
Our existing guide to merchant account underwriting and company ownership structures explains why the legal entity, trading activity, ownership and settlement arrangements already matter during provider selection.
What Do the New Rules Mean for UK Merchants?
Most merchants will not be responsible for preparing the monthly card-sales return. That responsibility sits with the relevant reporting payment organisation.
However, merchants may be contacted to provide, confirm or correct information associated with their acquiring arrangement.
Merchant Readiness Checklist
- Check your registered company name and company number.
- Confirm your VAT registration details, where applicable.
- Make sure your merchant account reflects the correct legal entity.
- Review business contact and trading address information.
- Confirm which entity receives card settlement.
- Respond to legitimate information-verification requests from your payment provider.
This can be particularly relevant for businesses with several companies, multiple merchant identification numbers (MIDs), different trading brands or more complex payment flows.
For example, a group operating three UK companies may need to ensure that each acquiring arrangement correctly identifies the entity receiving settlement and the associated reportable details.
These arrangements also matter during underwriting, but the new reporting obligations reinforce the importance of accurate, consistent merchant records.
What About Platforms, Marketplaces and Complex Payment Structures?
Complex payment businesses may need to pay particular attention to which organisation has the relevant contractual and settlement responsibilities.
A marketplace might involve a platform operator, individual sellers, a payment facilitator and an acquiring partner.
The presence of several organisations within the payment chain does not automatically mean that every organisation has a separate monthly reporting obligation.
Instead, the legal structure, contractual arrangements and activities of each entity should be assessed against the regulations.
This is particularly important where:
- A platform processes payments involving multiple sellers.
- A PayFac operates with an underlying acquiring partner.
- Several legal entities operate under one brand.
- Businesses use multiple acquirers or merchant accounts.
- Settlement arrangements differ from the customer-facing trading structure.
For further background, see our Merchant of Record guide and Payment Facilitator overview.
What Should Acquirers and PayFacs Prepare Before 2028?
For organisations within scope, implementation is likely to involve more than adding a new reporting function to an existing system.
Providers should review the full requirements against their operating models and existing merchant data.
01. Confirm Reporting Responsibility
Assess which legal entities fall within scope and how reporting responsibility applies to acquiring and PayFac arrangements.
02. Review Merchant Data Quality
Identify missing merchant identifiers, inconsistent legal-entity information and records requiring verification.
03. Update Onboarding and KYB Processes
Ensure the required tax identifiers are requested, appropriately verified and recorded, with due consideration for data security.
04. Prepare Reporting Systems
Review HMRC's published schema, monthly data extraction, validation, submission procedures and error handling.
05. Plan Merchant Communications
Develop an appropriate process for requesting missing information from existing merchants and explaining why additional details are needed.
06. Prepare for HMRC Notification
In-scope acquirers must notify HMRC before their first reportable month begins. HMRC has indicated that further details of the registration portal will be published.
Reporting Deadlines, Record Keeping and Compliance
Relevant merchant acquirers must provide monthly ongoing data no later than 21 days after the end of each reportable month.
The regulations also impose requirements relating to verification, notifications and retention of relevant records.
Under Regulation 16, the specified data and associated verification records must generally be preserved for five years after the end of the relevant reporting period.
Failure to comply with certain obligations can result in penalties under the applicable legislative framework.
Reporting organisations should review the regulations and HMRC's published due diligence and notification guidance when planning implementation.
Will These Rules Change Merchant Account Applications?
The regulations do not prescribe a single merchant application process or require every payment provider to adopt identical onboarding systems.
However, where new data requirements apply, payment providers may need to adjust the information they collect and the checks they perform.
Merchants switching providers, opening additional accounts or establishing more complex acquiring arrangements may therefore encounter additional verification requests.
That does not mean a business with a complex ownership structure is unsuitable for acquiring. It means the correct legal entity, relevant identifiers and payment arrangements need to be understood.
Merchant Advice Service Perspective
Accurate Merchant Information Matters Before and After Approval
Merchant onboarding has always required providers to understand the legal entity, ownership, trading activity and payment flow. The new HMRC reporting framework adds another reason for maintaining accurate merchant data throughout the acquiring relationship, rather than treating onboarding as a one-off administrative exercise.
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Key Takeaways
- New HMRC reporting regulations were laid on 3 November 2026.
- The regulations commence on 1 March 2028, with monthly card-sales reporting from April 2028.
- Relevant acquirers must report within 21 days of each month-end.
- Additional merchant identification and verification requirements apply.
- Payment facilitators and other payment organisations should assess their precise legal and contractual responsibilities.
- Merchants may be asked to confirm company and tax identification information.
- The legislation does not impose a new tax on card transactions.
Sources & Editorial Information
This guide is based on the regulations and HMRC materials published in November 2026. The following primary sources provide the official legal and implementation details.
Official Sources
Our Editorial Approach
Merchant Advice Service publishes independent payments guidance informed by official sources, industry research and practical experience working with merchants and payment providers.
We are an independent provider-matching service, not HMRC or a regulatory authority. We may receive commission from providers following successful introductions. Our matching service is free to businesses.
This article provides general information, not tax or legal advice. Reporting obligations depend on the activities and circumstances of the relevant organisation. Providers should consult the regulations, HMRC guidance and appropriate professional advisers.