New Mastercard Requirements For Subscription And Negative Option Billing Models

Mastercard recently announced new requirements for merchants using a subscription billing model or negative option model, or both.  The new standards focus on disclosures made to consumers at the point of payment; providing adequate confirmation, notices, and billing receipts; and affording customers an online or electronic cancellation method.  Requirements relating to point of payment disclosures become effective on September 22, 2022.  The other requirements will become effective much sooner, on March 22, 2022.  As always, reconciling card brand requirements with current federal and state legal requirements and law enforcement priorities will take particular care and attention, particularly as laws in California and other states continue to evolve.