Merchant Account Underwriting: What Payment Providers Check Before Approval

Merchant account underwriting is the process a payment provider or acquiring bank uses to understand a business before deciding whether it is prepared to process payments for it, and on what terms.

For a straightforward UK business, underwriting may be relatively simple.

For a larger or more complex company, it can involve much more than confirming a company number and checking a director's identity.

An underwriter may need to understand:

• which legal entity is applying;
• who ultimately owns and controls it;
• corporate shareholders and holding companies;
• ultimate beneficial owners (UBOs);
• overseas parent companies;
• group and subsidiary structures;
• the company's websites and trading brands;
• which legal entity contracts with customers;
• where customer money is received;
• how funds move between different businesses;
• what the merchant actually sells;
• Merchant Category Code (MCC);
• regulated activities and licences;
• processing history;
• chargebacks and refunds;
• financial strength;
• future-delivery exposure;
• transaction values;
• customer geography;
• settlement requirements; and
• payment technology and integrations.

For complex businesses, the central underwriting question is often not simply:

“Is this company legitimate?”

It is:

“Who is the merchant, who owns and controls it, what exactly is being processed, where does the money go, and what financial exposure does the acquiring relationship create?”

This guide explains what payment providers check during merchant underwriting, how company and group ownership can affect KYB, what UBOs and PSCs mean, which entity should apply for the merchant account, and what established businesses can prepare before switching or adding an acquiring provider.

Quick Summary

• Merchant underwriting is the provider's assessment of the business before approving card processing.
• KYB, KYC and merchant underwriting are related but are not exactly the same thing.
• KYB establishes and verifies the business.
• KYC identifies and verifies relevant individuals.
• Underwriting looks more broadly at whether the acquiring relationship is acceptable and on what terms.
• Visa requires acquirers to operate risk-based merchant onboarding and KYC/KYB processes.
• Current Visa standards include verification of principals/directors, ownership information, business registration, sanctions screening and additional ecommerce checks.
• Acquirers may also use website checks, negative-news screening, beneficial-owner research and other first- and third-party data.
• Companies House records can support verification, but they should not be assumed to replace the payment provider's own checks.
• UK Companies House guidance generally describes a PSC as someone with more than 25% of shares or voting rights, the ability to appoint/remove a majority of directors, or other significant influence or control.
• Since November 2025, Companies House identity verification has become a legal requirement for directors and PSCs according to the applicable implementation timetable.
• An ownership chain may need to be traced through corporate shareholders until the individuals who ultimately own or control the business can be identified.
• Private-equity, institutional and overseas ownership can require additional explanation even where the ownership itself is entirely ordinary and legitimate.
• The entity shown on the website should make sense when compared with the merchant application, customer contract and payment flow.
• Businesses should not assume that several group companies can simply process through one merchant account.
• Where several legal entities, countries, brands or business activities are involved, the acquiring structure may need several MIDs or merchant arrangements.
• Financial-services, marketplace and platform businesses should pay particular attention to which entity receives customer money and what happens to it afterwards.
• Strong financials and processing history can support underwriting but do not create automatic acceptance.
• A provider can approve a merchant subject to reserves, settlement conditions, processing caps or other requirements.
• Technical fit can form part of the overall provider decision, particularly where complex API, recurring-payment or platform requirements exist.
• The MAS underwriting framework is: Entity → Ownership → Activity → Money Flow → Processing → Financials → Risk → Technology.

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What Is Merchant Account Underwriting?

Merchant-account underwriting is the assessment undertaken before an acquiring bank or payment provider decides whether to establish a processing relationship with a business.

The exact process differs by provider and merchant.

A straightforward UK retailer with immediate fulfilment, low transaction values and a simple ownership structure may require substantially less investigation than a multinational group processing millions of pounds through several websites and legal entities.

Underwriting can consider several different types of risk:

• identity and ownership risk;
• financial risk;
• credit exposure;
• fraud risk;
• chargeback and dispute risk;
• regulatory risk;
• sector and business-model risk;
• reputational risk;
• future-delivery exposure;
• geographical risk;
• payment-flow risk; and
• technical or operational fit.

Visa's current Acceptance Risk Standards require acquirers to maintain risk-based onboarding processes and carry out KYC/KYB checks in accordance with applicable law.

MAS View

Underwriting should not be thought of simply as an identity check.

For larger merchants, it is closer to building a complete picture of:

who the business is + who controls it + what it sells + how money moves + what payment exposure exists.

What Is the Difference Between KYB, KYC and Merchant Underwriting?

The terms are often used together, but they describe different parts of the process.

Process	What It Broadly Establishes
KYB – Know Your Business	What the legal entity is, where it is registered, what it does and whether the business information can be verified.
KYC – Know Your Customer	The identity of relevant individuals connected with the business, such as directors, principals and beneficial owners where applicable.
Merchant underwriting	Whether the provider is prepared to support the overall merchant and payment risk, and on what commercial/risk terms.

A business can therefore successfully pass identity verification and still fail merchant underwriting.

For example, the provider might be completely satisfied that:

• the company exists;
• the directors are genuine;
• the owners have been identified; and
• the bank account belongs to the company;

but still decide that:

• the sector falls outside its risk appetite;
• future-delivery exposure is too high;
• the financial position is insufficient for the proposed volume;
• the payment flow is unsupported;
• the customer geography is outside its appetite; or
• the technical arrangement cannot be supported.

Our Payment Provider Risk Appetite guide explains why two providers can make different decisions about the same business.

What Does Visa Require Acquirers to Check?

Visa's current Acceptance Risk Standards require acquirers to operate risk-based merchant onboarding.

The published standards include KYC/KYB controls involving areas such as:

• principal and director information;
• identity verification;
• ownership information;
• business licences or registrations where applicable;
• sanctions screening;
• ecommerce URLs;
• verification of merchant websites/domains; and
• merchant activity and geography.

Visa's guidance also refers to the use of techniques including:

• web crawling;
• negative-news screening;
• beneficial-owner research;
• merchant domicile checks;
• business-activity checks;
• industry checks; and
• geographical checks.

The precise checks applied to an individual UK merchant remain provider-specific and must also reflect applicable law and regulation.

MAS View

Do not assume the underwriter is looking only at the documents you upload.

Information can be compared across multiple sources.

That makes consistency important.

Why Does Company Structure Matter in Merchant Underwriting?

Because the company applying for the merchant account may only be one part of a larger ownership structure.

For example:

Trading Company Ltd
↓
UK Holdings Ltd
↓
European Parent SA
↓
Ultimate owners / controlling persons

The provider may need to understand the ownership chain rather than stopping at the first corporate shareholder.

Larger businesses can include:

• holding companies;
• subsidiaries;
• corporate shareholders;
• overseas parent companies;
• private-equity investors;
• institutional investors;
• trust ownership;
• joint ventures;
• several trading entities;
• different legal entities for different countries;
• several websites and brands; and
• different entities owning IP, stock, property or customer contracts.

None of these structures automatically makes a merchant problematic.

But complexity can increase the amount of information required to understand the business.

What Is a UBO?

UBO means ultimate beneficial owner.

In practical terms, this means looking beyond a company that legally owns shares to understand the individual or individuals who ultimately own or control the corporate structure.

For example:

Merchant Ltd
100% owned by
Holding Company Ltd
owned by
Individual A – 60%
Individual B – 40%

Simply recording “Holding Company Ltd owns the merchant” may not tell the provider who ultimately controls the structure.

UK Money Laundering Regulations define beneficial ownership of many corporate bodies by reference to individuals who ultimately own or control more than 25% of shares or voting rights, exercise ultimate control over management or otherwise meet relevant control tests.

Important

The 25% threshold is not a rule saying that anyone holding 25% or less can always be ignored.

Control can exist through mechanisms other than simple share ownership.

The circumstances and applicable legal requirements matter.

MAS View

Legal shareholder and ultimate beneficial owner are not always the same thing.

For a simple owner-managed company they may be identical.

For a complex corporate group they may be several levels apart.

What Is a Person With Significant Control?

A UK Person with Significant Control (PSC) is a Companies House concept relating to individuals who own or control a company.

Companies House says a PSC is usually somebody who:

• has more than 25% of the company's shares;
• has more than 25% of voting rights;
• can appoint or remove a majority of directors; or
• otherwise exercises significant influence or control.

PSC information can be useful during KYB because it helps provide a public record of company control.

However, PSC and UBO should not simply be treated as interchangeable labels in every situation.

The payment provider must perform the checks required under its own applicable AML, scheme and underwriting framework.

Do Directors and PSCs Now Have to Verify Their Identity With Companies House?

Yes, under the Companies House identity-verification regime introduced as part of the Economic Crime and Corporate Transparency reforms.

Companies House states that identity verification became a legal requirement from 18 November 2025.

Current guidance requires directors and PSCs to provide their Companies House personal code according to the applicable timetable.

For existing directors, this is linked to the company's confirmation-statement process.

PSCs also have specific periods in which they must provide their verification information.

Does Companies House Identity Verification Replace Payment Provider KYC?

No.

This is an important distinction.

Companies House identity verification and merchant-account KYC/KYB operate for different purposes.

A payment provider can still be required to conduct its own checks under:

• applicable law;
• AML requirements;
• card-scheme requirements;
• banking-partner requirements;
• its underwriting policy; and
• its own risk controls.

MAS View

Companies House becoming more verified should make corporate information more useful.

It does not mean a merchant can tell an acquirer:

“Companies House verified us, so you do not need to.”

What Happens When a Company Is Owned by Another Company?

Corporate shareholders are common in larger businesses.

For example:

Operating Company Ltd
↓ 100% owned by
UK Group Holdings Ltd

The provider may need to determine who owns or controls UK Group Holdings Ltd.

If that company is itself owned by another legal entity, the ownership exercise can continue through the structure.

HMRC guidance on beneficial-owner identification specifically describes following linked corporate ownership until the relevant ultimate owners have been identified.

For a larger group, preparing an ownership chart before applying can therefore make underwriting significantly easier.

What Should a Company Ownership Chart Show?

For a complex merchant, a useful ownership chart can show:

• the merchant legal entity;
• company registration number;
• country of incorporation;
• percentage ownership;
• direct corporate shareholders;
• intermediate holding companies;
• ultimate parent;
• relevant individuals who ultimately own/control the structure;
• other group entities relevant to the payment arrangement; and
• where appropriate, regulated entities within the group.

Example

Global Parent Inc — USA
↓ 100%
European Holdings BV — Netherlands
↓ 100%
UK Trading Ltd — United Kingdom
↓
UK merchant account

An underwriter may then need information relating to both the UK applicant and the entities or individuals controlling it.

MAS View

For complex ownership, send the provider a diagram before it has to reconstruct the group from individual documents.

A clear ownership chart can answer in one page what would otherwise create several rounds of underwriting questions.

Does Overseas Ownership Make Merchant Underwriting More Difficult?

Not automatically.

Many large UK companies are owned by international groups.

However, an overseas ownership chain can require additional verification because the provider may need to understand:

• foreign legal entities;
• registration information;
• directors;
• ultimate owners;
• jurisdiction;
• corporate documents;
• sanctions exposure;
• business activities;
• source of ownership information; and
• how the UK merchant sits within the wider group.

The level of investigation will depend on the jurisdictions and corporate structure involved.

Provider risk appetite can also vary by country.

What If the Company Is Private-Equity Owned?

Private-equity ownership is common among larger UK businesses and does not in itself make a merchant unusual.

But it can make the ownership picture more complex.

For example:

Trading Company
↓
Holding Company
↓
Acquisition Vehicle
↓
Investment Fund / investment structure

The provider may ask for information sufficient to understand:

• the legal ownership chain;
• who controls the relevant entities;
• the fund or institutional ownership structure;
• directors and authorised signatories;
• the merchant's relationship with the wider group; and
• any individuals requiring verification under applicable requirements.

The documents needed will depend on the specific structure and provider.

What If No Individual Owns More Than 25%?

This can happen in businesses with dispersed ownership.

It does not mean the provider simply abandons the ownership review.

UK PSC rules also consider:

• voting rights;
• rights to appoint or remove directors; and
• significant influence or control.

AML processes can similarly require reasonable measures to understand ownership and control rather than relying solely on one percentage test.

The provider may therefore ask who exercises control over the company and who holds senior management responsibility where applicable under the relevant rules.

What If a Trust Is Part of the Ownership Structure?

Trust structures can create additional complexity because the relevant parties can include:

• settlor;
• trustees;
• beneficiaries or classes of beneficiaries;
• persons exercising control; and
• companies owned or controlled by the trust.

The Money Laundering Regulations contain specific beneficial-ownership provisions for trusts.

A merchant with trust ownership should expect the provider to request enough information to understand the arrangement and the relevant controlling parties.

Complex trust structures may also require specialist legal or compliance advice.

Does the Trading Name Matter During Merchant Underwriting?

Yes, but the trading name is not necessarily the legal merchant entity.

For example:

Website: ExamplePay.co.uk

Trading brand: ExamplePay

Legal company: Example Holdings UK Limited

The payment provider needs to know which legal entity is actually:

• contracting with the customer;
• selling the goods or services;
• accepting the payment;
• responsible for refunds;
• responsible for customer obligations; and
• receiving settlement.

The website should normally make the legal relationship clear.

MAS View

Brand ≠ legal entity.

A recognised trading name can be commercially important, but underwriting still needs to establish which company sits behind it.

Which Legal Entity Should Hold the Merchant Account?

There is no single rule that can be applied to every corporate group.

However, the entity applying for the merchant account should make sense when compared with:

• the customer contract;
• business activity;
• website;
• invoices;
• refund obligations;
• regulatory permissions;
• bank account;
• funds flow; and
• the acquiring structure.

For example, problems can arise where:

Customer contracts with Company A

but:

Company B takes the card payment

and:

Company C receives settlement.

That structure may have a perfectly legitimate explanation.

But the provider needs to understand it.

MAS View

The entity taking the payment should make sense within the customer contract, business model and funds flow.

If it does not look obvious on paper, explain it before underwriting has to ask.

Can Several Companies in a Group Use One Merchant Account?

Businesses should not assume that a merchant account approved for one legal entity can simply be used by other group companies.

The acquiring arrangement is established on the basis of the merchant that was underwritten.

Using the facility for transactions belonging to another entity can create issues around:

• merchant identification;
• MCC;
• customer contracting entity;
• settlement;
• refunds;
• tax and accounting;
• regulatory responsibility;
• scheme data; and
• transaction laundering/miscoding concerns.

Larger groups should establish with the provider whether they need:

• separate merchant accounts;
• separate MIDs;
• a group acquiring agreement;
• multi-entity acquiring;
• different acquiring arrangements by country; or
• another approved group structure.

What Is a MID?

A Merchant ID or MID is an identifier used within the merchant's acquiring arrangement.

Large businesses can have more than one MID.

Separate MIDs can potentially be relevant where a merchant has:

• multiple legal entities;
• different business activities;
• different Merchant Category Codes;
• several countries;
• different websites or brands;
• card-present and ecommerce channels;
• different currencies;
• distinct risk profiles; or
• operational/reporting requirements.

The appropriate MID structure is provider-specific.

What If the Regulated Entity and Merchant Entity Are Different?

This deserves particular attention.

Consider a financial-services group:

Company A — FCA-authorised entity
Company B — customer-facing trading company
Company C — technology/IP company

If Company B applies for the merchant account while Company A holds the relevant regulatory permissions, the provider may need to understand:

• which entity performs the regulated activity;
• which entity contracts with customers;
• which entity receives payment;
• why those entities differ;
• the commercial agreements between them;
• what the payment represents;
• whether Company B is permitted to receive the funds; and
• how money moves through the group.

Being part of the same corporate group does not automatically make the legal entities interchangeable.

Our Financial Services Merchant Accounts guide explains the additional issues that can arise for regulated businesses.

Why Does Funds Flow Matter?

An underwriter needs to understand what happens to customer money.

For a simple merchant:

customer → merchant → merchant supplies its own product/service

For a more complex platform:

customer → platform → third-party seller/service provider

Those are not necessarily the same acquiring model.

The FCA specifically warns that businesses such as marketplaces and booking services may potentially be providing payment services where they receive customer money before passing it to another party.

This means merchant underwriting can overlap with wider payment-services-perimeter questions.

MAS View

For complex businesses, draw the payment flow.

Show:

who pays → who receives → who controls → who settles → who ultimately keeps the money.

Do this before selecting the acquiring model.

What Is a Merchant Funds-Flow Diagram?

A simple funds-flow diagram can show:

• customer;
• checkout;
• payment provider;
• merchant legal entity;
• platform where relevant;
• third-party sellers or service providers;
• bank accounts;
• settlement;
• refund flow; and
• any split or onward payment.

Example: Direct Merchant

Customer
↓ card payment
Acquirer / PSP
↓ settlement
Trading Company Ltd

Example: Multi-Party Model

Customer
↓
Platform
↓
Payment arrangement
↓
Seller / service provider

The second structure requires considerably more explanation.

What Business Information Does an Underwriter Check?

Providers can request information including:

• company name;
• company number;
• registered address;
• trading address;
• incorporation date;
• business activity;
• trading names;
• websites;
• directors;
• shareholders;
• beneficial owners;
• ownership percentages;
• bank account;
• contact information;
• countries of operation;
• licences;
• regulatory status; and
• group-company information.

Does the Website Get Checked During Underwriting?

Yes, particularly for ecommerce merchants.

Visa's current acquiring standards expressly refer to collecting ecommerce URLs and verifying merchant websites/domains.

An underwriter may look for information such as:

• what is being sold;
• pricing;
• legal entity;
• contact information;
• terms and conditions;
• refund policy;
• cancellation policy;
• delivery information;
• privacy information;
• subscription terms;
• regulated claims;
• customer journey; and
• countries served.

Website information should be consistent with the merchant application.

MAS View

If the application says:

“UK professional-services consultancy”

but the website appears to sell:

international investment products

expect questions.

The issue is not just wording. The underwriter needs to understand the real activity being processed.

Does the MCC Get Checked During Underwriting?

Yes.

A Merchant Category Code classifies the merchant's principal business activity within the card-payment ecosystem.

MCC can influence:

• provider eligibility;
• scheme requirements;
• risk policies;
• transaction treatment;
• monitoring; and
• pricing in some circumstances.

But MCC does not replace underwriting.

Two businesses with the same MCC can present completely different financial and operational risks.

Read our Merchant Category Codes (MCC) guide.

What Financial Information Does an Acquirer Check?

The level of financial review depends on the merchant.

A provider may request:

• filed accounts;
• management accounts;
• bank statements;
• balance-sheet information;
• profit-and-loss information;
• cash-flow information;
• financial forecasts;
• funding information;
• group accounts;
• parent-company information; or
• other evidence relevant to the acquiring exposure.

The financial review can become particularly important where the merchant has:

• large processing volumes;
• high transaction values;
• future delivery;
• significant refunds;
• rapid growth;
• seasonality;
• limited processing history;
• a weak balance sheet; or
• large outstanding customer obligations.

Why Does a £10m or £50m Merchant Still Need Underwriting?

High processing volume does not remove acquiring risk.

In fact, larger volume can create greater financial exposure.

A merchant processing £20 million annually may be commercially attractive to an acquirer, but the provider still needs to understand:

• where the volume comes from;
• processing history;
• customer geography;
• transaction values;
• refunds;
• chargebacks;
• business model;
• financial position;
• future customer obligations;
• seasonality;
• group structure; and
• technology.

MAS View

High volume can increase commercial value and acquiring exposure at the same time.

Large merchants are not necessarily easier to underwrite. They may simply be worth underwriting in more detail.

Why Do Payment Providers Ask for Processing Statements?

Previous processing statements can provide evidence of what the merchant has actually done rather than what it forecasts it will do.

They can help show:

• monthly card volume;
• transaction count;
• average transaction value;
• refunds;
• chargebacks;
• seasonality;
• currencies;
• international activity;
• historic provider relationship; and
• changes in processing over time.

An established merchant should therefore generally expect to provide processing history where relevant.

Can Strong Processing History Speed Up Underwriting?

It can make the merchant easier to evidence, but it does not guarantee a particular onboarding timeframe.

The MerchantRoute Merchant Onboarding Study, published by Merchant Advice Service, found that onboarding time varies considerably according to merchant complexity.

In the study:

• 52% of respondents said a straightforward merchant could typically be approved within 1–3 working days; while
• 18% said onboarding could take more than one month.

The research also found that 41% of respondents identified poor provider or risk fit as a contributor to merchant-account declines.

MAS View

For a complex merchant, the objective should not be:

“How do we make underwriting artificially fast?”

It should be:

“How do we give the right provider a complete, coherent application the first time?”

How Do Chargebacks and Refunds Affect Underwriting?

An established merchant's dispute history can form part of the risk assessment.

A provider may consider:

• historic chargeback levels;
• refund volumes;
• reasons for disputes;
• fraud;
• recent trends;
• transaction values;
• seasonal spikes; and
• steps taken to reduce recurring issues.

High dispute activity does not necessarily create an automatic decline.

But it can influence:

• provider appetite;
• reserve requirements;
• settlement;
• pricing;
• monitoring; or
• the level of underwriting required.

How Does Future Delivery Affect Merchant Underwriting?

Future delivery occurs where customers pay before the merchant fully provides the goods or services.

An underwriter may want to understand:

• how much customers pay in advance;
• average fulfilment period;
• maximum fulfilment period;
• outstanding customer obligations;
• peak seasonal exposure;
• financial capacity;
• refund history;
• chargebacks; and
• how the business would support customers if fulfilment were interrupted.

Our Future-Delivery Risk in Payments guide explains how monthly processing and outstanding customer exposure can be very different figures.

Can Underwriting Result in a Rolling Reserve?

Yes, potentially.

Merchant underwriting does not always result in a simple:

approved / declined.

A provider may approve a merchant subject to risk terms such as:

• rolling reserve;
• fixed reserve;
• delayed settlement;
• processing cap;
• maximum transaction value;
• additional monitoring;
• geographical restrictions; or
• other contractual conditions.

Read our Merchant Account Rolling Reserves guide.

Does Regulation Affect Merchant Underwriting?

Yes, where the merchant operates a regulated business.

The provider may ask for evidence of relevant:

• FCA authorisation;
• FCA registration;
• appointed-representative status;
• gambling licence;
• professional registration;
• sector licence;
• overseas regulatory permission; or
• other authorisation applicable to the activity.

But regulatory status alone does not guarantee merchant-account acceptance.

The acquirer still needs to understand the payment activity.

Can an FCA-Regulated Business Still Fail Merchant Underwriting?

Yes.

FCA regulation and merchant-account underwriting answer different questions.

A regulated business may still have underwriting issues relating to:

• payment flow;
• customer geography;
• what customers are paying for;
• regulated entity versus processing entity;
• MCC;
• high transaction values;
• card-funded financial activity;
• chargebacks;
• provider appetite; or
• technical structure.

See our Financial Services Merchant Accounts guide.

Do Payment Providers Check Sanctions, PEPs and Adverse Information?

Providers can conduct screening relating to financial-crime and merchant risk.

Visa's current acquiring standards specifically require applicable sanctions screening and refer to methods including negative-news scanning and beneficial-owner research.

Depending on the merchant and applicable requirements, due-diligence processes can involve:

• sanctions screening;
• politically exposed person (PEP) checks;
• adverse-media searches;
• director and UBO research;
• associated-company checks;
• previous merchant history; and
• other fraud or financial-crime indicators.

The precise process is provider-specific.

Do Payment Providers Check Associated Companies?

Potentially.

Where ownership, directors, websites, bank accounts or previous payment activity connect the merchant with other businesses, those relationships can become relevant to underwriting.

This can be particularly important where:

• a director previously operated another merchant;
• a group company had a previous acquiring relationship;
• several businesses share websites or contact details;
• ownership has recently changed;
• business activity has moved between legal entities; or
• a previous merchant facility was terminated.

Our Terminated Merchant Facilities guide explains why connected merchant information can matter following account closure.

Does Previous Merchant Account Termination Affect Underwriting?

Potentially.

A provider may want to know:

• which provider terminated the account;
• when;
• why;
• whether processing limits were exceeded;
• whether fraud or disputes were involved;
• whether the business changed;
• whether provider appetite changed;
• whether another group entity was involved; and
• what has happened since termination.

A previous termination should be explained accurately.

A provider exiting a sector is very different from termination following serious fraud or scheme issues.

Do MATCH Pro and Visa Merchant Screening Form Part of Underwriting?

Card-scheme merchant-screening information can form part of acquiring due diligence.

Mastercard operates MATCH Pro and Visa operates Visa Merchant Screening Service.

These should not be confused with ordinary provider-risk decisions.

A merchant being declined because it falls outside one provider's appetite does not automatically mean it has been listed within a card-scheme merchant-screening system.

Read our Merchant Account Declined guide for more detail.

Does Technology Form Part of Merchant Underwriting?

It can form part of the overall provider-fit assessment.

A business may be acceptable financially but still require payment functionality the provider cannot support.

This becomes particularly relevant for larger merchants needing:

• custom API integration;
• multiple MIDs;
• network tokenisation;
• subscriptions;
• recurring billing;
• stored credentials;
• account updater;
• split payments;
• marketplace payments;
• international acquiring;
• multiple currencies;
• booking-system integration;
• EPOS integration;
• ERP integration;
• CRM integration;
• complex reconciliation; or
• multi-provider routing.

Our Integrated Payments Solutions guide explains why technical fit should be established before provider selection.

MAS View

A merchant can pass underwriting and still choose the wrong provider.

Provider selection requires:

Underwriting Fit + Technical Fit + Commercial Fit.

What Documents Might a Large Merchant Need for Underwriting?

The exact requirements depend on the provider and merchant.

However, an established or complex business could be asked for information across several categories.

Corporate

• certificate of incorporation;
• company registration details;
• group structure;
• ownership chart;
• shareholder information;
• director information;
• UBO information;
• corporate shareholder information;
• trading names;
• websites; and
• group-company relationships.

Identity

• director identification;
• beneficial-owner identification;
• proof of address where required;
• authorised signatories; and
• other relevant control-person information.

Financial

• filed accounts;
• management accounts;
• bank statements;
• financial forecasts;
• group accounts;
• funding information; and
• other evidence requested by underwriting.

Payments

• processing statements;
• monthly card volume;
• average transaction value;
• maximum transaction value;
• refund history;
• chargeback history;
• currencies;
• customer countries;
• current provider;
• reserve terms;
• settlement terms; and
• processing limits.

Operations

• terms and conditions;
• refund policy;
• cancellation policy;
• delivery information;
• customer contracts;
• fulfilment information;
• supplier information;
• outstanding customer obligations; and
• future-delivery data.

Regulatory

• FCA status;
• licences;
• registrations;
• permissions;
• sector-specific approvals; and
• relevant overseas regulatory information.

Technical

• gateway requirements;
• API specification;
• platform;
• integration requirements;
• payment-flow diagram;
• recurring-payment model;
• marketplace model;
• PCI responsibilities; and
• reconciliation requirements.

What Usually Slows Merchant Underwriting Down?

Common causes can include:

• incomplete ownership information;
• complex corporate structures provided without an ownership chart;
• missing director or UBO information;
• different company names across the website, application and bank account;
• unclear payment flow;
• unclear regulated entity;
• missing financial information;
• unexplained processing spikes;
• future-delivery exposure not quantified;
• previous chargebacks not explained;
• historic account termination;
• websites not ready for review;
• missing policies;
• unsupported countries;
• unclear Merchant Category Code;
• technical requirements disclosed too late; and
• applying to a provider without suitable risk appetite.

MAS View

For complex merchants, underwriting delays are often caused by missing context rather than missing passports.

The underwriter needs to understand how all the pieces connect.

How Can a Complex Merchant Prepare Before Applying?

Create an underwriting pack before approaching providers.

For a larger business, we would suggest preparing information under the following headings.

1. Entity

Which legal company is applying and why?

2. Ownership

Who owns and controls the applicant?

Include an ownership chart where the structure is not obvious.

3. Activity

What does the merchant actually sell?

Which MCC is relevant?

4. Money Flow

Who pays whom?

Which entity receives settlement?

Does money move to third parties?

5. Processing

Provide actual or forecast:

• monthly volume;
• annual volume;
• average transaction value;
• maximum transaction value;
• customer geography;
• refunds;
• chargebacks; and
• seasonality.

6. Financials

What evidence demonstrates the company's financial position and capacity?

7. Risk

Explain:

• future delivery;
• historic disputes;
• high transaction values;
• regulated activity;
• previous processing issues; and
• other relevant merchant risks.

8. Technology

What does the payment provider actually need to deliver?

MAS Underwriting Framework

Entity → Ownership → Activity → Money Flow → Processing → Financials → Risk → Technology.

This is not an official card-scheme underwriting formula.

It is the Merchant Advice Service framework for organising the information a complex merchant should understand before provider selection.

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Merchant Underwriting Example: Complex UK Group

Consider the following hypothetical merchant.

Area	Example
UK card turnover	£18 million annually
Trading entities	3
Websites	5
Parent company	EU holding company
Ownership	Institutional / investment structure
Customer countries	UK and EEA
Average transaction	£850
Maximum transaction	£12,000
Fulfilment	Same day to 6 months
Processing	Ecommerce + telephone + recurring
Technology	Custom API + CRM integration

This is not simply an £18 million pricing exercise.

The provider needs to understand:

• which entity processes which revenue;
• how the group is owned;
• who the relevant UBOs/control persons are;
• whether all five websites belong to the same merchant;
• whether several MCCs are needed;
• which countries each entity serves;
• future-delivery exposure;
• historic processing performance;
• financial strength;
• refund and chargeback history;
• required MIDs;
• API requirements; and
• commercial terms.

MAS View

This is why larger merchants should not begin a payment-provider review by asking for a transaction rate.

The first job is to define what actually needs underwriting.

Should a Merchant Apply Before the Ownership Structure Is Clear?

For a complex company, usually it is better to clarify the structure first.

If the provider receives:

• one legal entity on the application;
• another on the website;
• another on the bank statement;
• an unexplained parent company;
• missing corporate shareholders; and
• an unclear UBO position;

additional questions are predictable.

That does not mean the business is unacceptable.

It means the underwriter does not yet have a coherent picture.

Should Established Merchants Complete Several Applications at Once?

Not necessarily.

It can make sense to compare several potential providers, but there is a difference between:

comparing acquiring options

and:

submitting full underwriting applications to unsuitable providers.

Before formal applications are submitted, compare:

• provider risk appetite;
• sector;
• MCC;
• company-country support;
• customer geography;
• group structure;
• processing volume;
• transaction values;
• future delivery;
• integration;
• settlement;
• reserve requirements;
• pricing; and
• contract terms.

Can a Merchant Pass Underwriting but Still Get a Poor Payment Deal?

Yes.

Acceptance is only one part of provider selection.

A merchant should also compare:

Area	What to Check
Acceptance	Does the provider genuinely support the merchant?
Structure	Can it support the required entities, MIDs and countries?
Technology	Does it support the gateway, API and integrations?
Settlement	When are funds available?
Reserve	Are funds retained and on what terms?
Pricing	What is the complete processing cost?
FX	How are international transactions and settlement priced?
Contract	What are the term, renewal and termination provisions?
Operations	How do reporting, reconciliation, disputes and support work?

MAS View

Approved does not mean suitable.

The best acquiring arrangement needs to pass:

Underwriting Fit → Structural Fit → Technical Fit → Operational Fit → Commercial Fit.

How Merchant Advice Service Helps With Merchant Underwriting

Merchant Advice Service does not underwrite merchants or make payment-provider approval decisions.

Our role is to help businesses understand their payment requirements and identify providers that may fit before a formal application is submitted.

For larger or more complex merchants, this can involve understanding:

• legal entity;
• group structure;
• ownership;
• UBOs;
• business activity;
• MCC;
• regulatory status;
• funds flow;
• processing volume;
• transaction values;
• customer countries;
• future-delivery exposure;
• processing history;
• chargebacks;
• refunds;
• financial profile;
• previous provider;
• existing reserve;
• settlement;
• gateway;
• API;
• platform;
• integrations;
• international acquiring;
• currencies;
• pricing; and
• contract requirements.

The payment provider then conducts its own KYB, KYC and underwriting and decides whether to offer processing and on what terms.

The Payments Directory® is designed to help narrow provider options according to the merchant's actual requirements.

You can also read How Merchant Advice Service Works and our Research & Comparison Methodology.

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Sources & Further Reading

Visa — Visa Acceptance Risk Standards

Visa's current acquiring-risk framework covers acquirer risk appetite, merchant onboarding, KYC/KYB, merchant ownership information, ecommerce website verification, fraud checks, beneficial-owner research and ongoing monitoring.

Companies House — People With Significant Control

Companies House guidance explains how UK companies identify PSCs, including share ownership, voting rights, board appointment rights and other forms of significant influence or control.

Companies House — Identity Verification

Companies House guidance explains the mandatory identity-verification requirements introduced for directors and PSCs and the current timetable for providing personal codes.

Money Laundering Regulations 2017

The Money Laundering Regulations contain the UK legal definitions relevant to beneficial ownership of companies, partnerships and trusts, including direct and indirect ownership and control.

Financial Conduct Authority — Merchant Acquiring

The FCA defines acquiring payment transactions as a payment service involving a payment-service provider contracting with a payee to accept and process payment transactions resulting in funds being transferred to the payee.

Financial Conduct Authority — Businesses Receiving Customer Funds

The FCA warns that businesses including marketplaces and booking services may potentially be providing payment services where customer money is received before being passed to another seller or service provider.

MerchantRoute Merchant Onboarding Study

Merchant Advice Service's industry validation research included 25 payments-industry respondents and examined merchant application, underwriting and onboarding. The study found that 41% identified poor provider or risk fit as a contributor to merchant-account declines.

Read the MerchantRoute Merchant Onboarding Study.

Related Merchant Advice Service Guidance

• Payment Provider Risk Appetite: Why Acquirers Accept Different Businesses
• Merchant Category Codes (MCC) Guide
• Future-Delivery Risk in Payments
• Why Do Merchant Account Applications Get Declined?
• High-Risk vs Low-Risk Merchant Accounts
• High-Risk Merchant Account Applications
• Terminated Merchant Facilities
• Merchant Account Rolling Reserves
• Financial Services Merchant Accounts
• Integrated Payments Solutions
• Payment Facilitators (PayFacs)
• Compare UK Payment Providers
• The Payments Directory®
• UK Merchant Account Application & Onboarding Study
• How Merchant Advice Service Works
• Research & Data
• Research & Comparison Methodology

Editorial & Commercial Disclosure

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 about merchant underwriting, company ownership or payment-provider requirements contained within this guide.

Merchant Advice Service is not an acquiring bank and does not conduct the payment provider's formal KYB, KYC or merchant underwriting.

Payment providers and acquiring banks establish their own underwriting policies subject to applicable laws, regulations, card-scheme requirements and partner arrangements.

The documentation requested and individuals requiring verification vary according to the merchant, provider, corporate structure and applicable legal requirements.

References to PSC and beneficial-ownership thresholds describe current UK rules in general terms and should not be used as a substitute for legal or AML advice in complex ownership structures.

Companies House identity verification does not replace a payment provider's own identity, AML or underwriting checks.

The MAS underwriting framework and examples in this guide are explanatory tools and are not official Visa, Mastercard, FCA or statutory underwriting methodologies.

Payment-provider, Companies House, FCA and card-scheme information last checked: 1 September 2026.

This guide provides general payments information and should not be treated as legal, regulatory, accounting, financial or formal compliance advice.