Payment provider contracts: what gambling operators should check
A payment contract decides when an operator gets its money, how much the provider can hold back, who pays if a card scheme fines someone, and how quickly the provider can walk away. For gambling, where providers treat the sector as high risk, these terms deserve a line-by-line read.
- Coverage
- General checklist; not legal advice
- Sources checked
- 24 October 2026
- Next review
- 24 April 2027
Key points
- Settlement timing and reserves decide the operator's cash flow; get them in writing, with how they are calculated and released.
- Card schemes treat gambling as high integrity risk, so expect clauses on scheme registration, fines and monitoring programmes.
- Termination and suspension rights matter more for gambling, where providers may exit the sector or a market.
- Make sure the contract supports regulatory duties such as payment-method restrictions, reporting and data access.
This checklist is general research, not legal advice. Have a qualified lawyer review any agreement before signing.
Parties and services
- Which legal entity provides each service (gateway, acquiring, payouts, open banking)? It should match the entity you checked on the regulator's register; see our due diligence guide.
- Which markets, currencies and payment methods are covered, and is gambling named explicitly as an accepted activity?
Money terms
- Settlement schedule. How many days after a transaction you are paid, cut-off times, and whether weekends and holidays count.
- Reserves. Rolling or fixed reserves: the percentage, how long funds are held, triggers for increases and the release schedule.
- Fees. Transaction, scheme, cross-border, currency conversion, refund, payout and chargeback fees, and how changes are notified.
- Netting. Whether fees, chargebacks and reserves are deducted from settlement, and how each appears in reports.
Card scheme terms
Visa classes gambling (MCC 7995) as a high integrity risk category requiring registration, and Mastercard's security rules include a registration section for non-face-to-face gambling merchants and a Business Risk Assessment and Mitigation programme. Contracts usually let the provider pass scheme fines and assessments to the merchant. Check:
- who completes and pays for scheme registration;
- when a scheme fine can be passed on, what evidence the provider must give, and whether you can contest it;
- dispute ratio thresholds and what happens if you exceed them.
Regulatory cooperation
- The provider's commitment to support your licence conditions, for example blocking credit cards where required (Great Britain's condition 6.1.2) and using only regulated payment services (condition 5.1.2).
- Correct merchant coding and stable descriptors; Visa bars dynamic descriptors for gambling merchants.
- Access to transaction data for regulators, auditors and AML investigations, and data retention periods.
- Notice of changes to the provider's own regulatory status.
Suspension and termination
- Grounds and notice periods for suspension or termination, including changes in the provider's risk appetite for gambling.
- What happens to reserves and pending settlements on termination, and the deadline for releasing them.
- Exit assistance: data export, token migration for stored cards, and continued payouts to players during a transition.
Service levels and reporting
- Uptime commitments, incident notification times and service credits.
- Report formats and delivery times that allow daily reconciliation; see our reconciliation guide.
Questions about payment provider contracts
What is a rolling reserve?
A share of each settlement the provider holds back for a set period to cover future chargebacks, refunds or fines, then releases on a schedule. The contract should state the percentage, holding period and release terms.
Can a payment provider pass card scheme fines to a gambling operator?
Contracts commonly allow it. Check what triggers a pass-through, what evidence the provider must supply and whether you can challenge the fine.
Sources
- Visa, Integrity Risk Program (April 2023) and Merchant Data Standards Manual (October 2026)
- Mastercard, Security Rules and Procedures, Merchant Edition (4 August 2026)
- Gambling Commission, LCCP conditions 5.1.2 and 6.1.2
- All sources checked 24 October 2026.