LINKS to ALL Regulatory Articles (Visa, MasterCard, European/PSD2 )can be found at the end of this article.
We want to remind you about upcoming changes to Visa's disclosure, notification and cancellation policies for transactions at merchants selling physical or digital goods or services offered as a subscription, free trial and introductory offer that automatically transition to recurring charges or billing.
The updated policies take effect on April 18 and include these requirements:
Express cardholder consent for transactions beyond the promotional period, and the requirement for merchants to provide a copy of the accepted terms and conditions to the cardholder at the time of enrollment
Reminder notification to cardholder at least 7 days prior to the end of the trial/introductory promotional discount period before billing
The cardholder must be able to easily cancel online, regardless of whether they initially signed up for the trial online. Ease of cancellation should be on par with the simplicity of clicking an unsubscribe button to stop receiving email notifications.
An additional descriptor indicating a trial period-related transaction will be required in the Merchant Name field for the first financial transaction at the end of the trial period. This descriptor (e.g., “trial,” “trial period,” “free trial”) will then appear on cardholder statements, online banking, mobile apps and SMS / text alerts.
sticky.io is implementing the following changes by 12 p.m. EST 04/16/2020 in response:
Auto-sending reminder notifications to cardholders at least 7 days prior to billing if a free trial period has ended. We will be automatically sending these notifications from the SMTP information located inside of your PaySafe Continuity gateway profile. For more information on these notifications please click here: https://support.sticky.io/en/articles/3926015-paysafe-standardized-consent-email-templates-sticky-io-visa
On Visa Rebill notifications, the descriptor value will include the additional verbiage "trial" while considering a 22-character maximum
Merchants utilizing NMI Paysafe Continuity Gateway and approved TPP Registered DRMs: Updates needed will be automatically enforced by Paysafe. The only action you need to take is adding the necessary disclosures to your landing pages, having clear terms and conditions outlining that it is a trial.
There is no consent notification for Visa transactions, so you must make it clear on the checkout page that the consumer is consenting to a subscription.
Non-Paysafe Merchants: You will need to build a subscription reminder to be compliant. See our Help Center documentation here for configuration steps: https://support.sticky.io/en/articles/3926293-sticky-io-set-up-for-visa-compliance
If you have any questions about these changes or how they may impact you, please contact your Client Success Manager or Customer Support at 1-800-455-9645 ext 1.
Our team is available Monday through Friday, 9 a.m. to 5 p.m. EST to assist.
ADDITIONAL REGULATORY ARTICLES