Visa and Mastercard Rules for Subscriptions and Free Trials

Visa and Mastercard both have specific rules for merchants that bill customers on a recurring basis. In short, you need express consent at sign-up, a reminder before a trial or introductory offer turns into a full charge, a receipt that explains the next charge, and a simple way to cancel online. Mastercard also requires merchants offering free trials of physical products to be registered under MCC 5968. Breaking these rules gives cardholders an easy chargeback and is a common reason acquirers close subscription accounts.

Who the rules apply to

The rules cover any merchant that stores a card and charges it again without the customer starting each payment. That includes software and media subscriptions, memberships, subscription boxes and continuity shipments of physical products. The strictest parts apply to free trials and introductory offers, where the customer pays nothing or a small amount first and is then moved to a full price automatically. Card schemes call that negative-option billing.

Visa's rules for trials and introductory offers

Visa's rules for trials and introductory offers have applied since 18 April 2020 and cover both physical and digital goods. A merchant has to:

  • Get the customer's express consent to the subscription at checkout, separate from accepting the general terms.
  • Send a confirmation with the trial terms, how to cancel and when the full charge starts.
  • Send a reminder at least seven days before the first full charge when the trial or offer is longer than seven days.
  • Offer online cancellation, however the customer signed up.
  • Show the word 'trial' in the billing descriptor of the first charge after the trial.
  • State on the receipt that the card will be charged unless the customer cancels.

Mastercard's rules for subscriptions and free trials

Mastercard first set rules for free trials of physical products in 2019, and broadened them to subscriptions and digital goods from 11 October 2022.

  • Merchants offering free trials of physical products must be registered under MCC 5968, and the trial starts when the customer receives the product.
  • Before charging after a trial, the merchant sends the price, the billing date and how to cancel.
  • Clear terms at sign-up, with the amount, frequency and how to cancel shown before the customer agrees.
  • A confirmation at sign-up and a receipt after every billing.
  • Notice before an annual renewal, so the customer can decide whether to continue.
  • A simple online cancellation route.

Dispute and fraud limits

Subscriptions live or die by their dispute ratio. Fraud and disputes are measured together under the Visa Acquirer Monitoring Program, and since 1 April 2026 a merchant in the EU or the US is classed as excessive at a ratio of 1.5% with at least 1,500 fraud and dispute counts in a month. Mastercard's Excessive Chargeback Merchant tier still requires at least 100 chargebacks in a month, and the ratio that triggers it is reported to fall from 1.5% in 2027 to 0.9% in 2031 under its new monitoring program.

Acquirers usually act long before those limits, because the acquirer is measured too. A subscription business that wants stable processing keeps its ratio well below 1%.

Try it with your own numbers

Chargeback ratio calculator

Work out the same figure for your own month before reading on.

What keeps a subscription account open

  • A checkout that shows the price after the trial, the billing frequency and how to cancel, next to the button the customer clicks.
  • Reminder and receipt emails that are sent automatically and that you can show to your acquirer.
  • A recognisable billing descriptor with your brand name and, where possible, a support URL or phone number.
  • Self-service cancellation in the customer account, without having to call or chat.
  • Fast refunds for customers who forgot to cancel, which costs less than a chargeback.
  • Chargeback alerts and 3-D Secure on the first payment, so fraud and disputes are caught early.
  • Account updater and network tokens, so renewals do not fail on reissued cards and turn into involuntary churn.

Local consumer law comes on top

Card scheme rules sit next to consumer law, not in place of it. In the US, the FTC's click-to-cancel rule was vacated by a federal appeals court in July 2025 before it took effect, but the Restore Online Shoppers' Confidence Act and many state auto-renewal laws still require clear terms, consent and a simple way to cancel. In the UK, the Digital Markets, Competition and Consumers Act 2024 introduces a subscription contracts regime with reminder notices, cooling-off periods and easy online cancellation, currently expected from January 2027.

How Acquipayer helps

Acquipayer is not a payment provider. You describe your billing model, products, markets and dispute figures once, and your profile is matched with a payment provider whose policy fits subscriptions like yours. Your account is then prepared with that provider. Final approval and terms are always the provider's decision.

Common questions

Do the card rules apply to monthly software subscriptions without a trial?

Yes, in part. Mastercard's rules on clear terms, receipts and online cancellation apply to subscriptions in general. Visa's strictest rules apply to trials and introductory offers, but clear terms and easy cancellation are expected of every recurring merchant.

How many days before a renewal do I need to remind customers?

For Visa trials and introductory offers longer than seven days, the reminder goes out at least seven days before the first full charge. For annual renewals, Mastercard expects notice before the renewal so the customer can cancel in time.

Sources

  • Visa, trial subscription rules, 2020.
  • Mastercard, Subscription and Negative Option Billing Model Summary, November 2022.
  • Visa Acquirer Monitoring Program, thresholds from 1 April 2026.
  • Mastercard, Global Merchant and Acquirer Program announcement, 2026.

MCC 5968

MCC 5968 is Direct Marketing: Continuity/Subscription Merchants. Card schemes use it for merchants that bill customers on a recurring basis, and they expect it for negative-option offers, where a free trial or introductory price turns into a recurring charge unless the customer cancels. Visa places card-absent negative-option merchants under 5968 in Tier 3 of its Integrity Risk Program, and Mastercard requires merchants offering free trials of physical products to be registered under it.

Chargeback ratio

Your chargeback ratio is the number of disputes in a month divided by a month of transactions, shown as a percentage. Mastercard flags merchants from 1.5% of chargebacks and Visa from 1.5% of fraud plus disputes in most regions, both with minimum counts, and most acquirers act before that. It is the number that decides whether you keep your account, so know exactly how your provider calculates it.

Chargeback alerts

Chargeback alerts tell you that a customer has contacted their bank about a payment before the bank files a chargeback. If you refund in time, the bank should not file a chargeback, so in most cases you avoid the chargeback fee and the case does not count as a dispute towards Visa's and Mastercard's limits. Alerts do not stop everything, though. A fraud report the bank has already filed still counts, and you still lose the sale.

Mastercard GMAP

From 1 April 2027, Mastercard brings its chargeback and fraud monitoring programs together under a Global Merchant Audit Program. The existing excessive chargeback and excessive fraud tiers continue, but the chargeback threshold falls step by step from 1.5% to 0.9% by 2031, and new dispute tiers count fraud reports even when no chargeback follows. Mastercard has not published the program openly, so the figures below come from industry and acquirer reports of its bulletin and should be checked with your acquirer.

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