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Merchant account underwriting checklist

To approve a merchant account for card payment processing, an underwriter must review your business. To help you prepare your application, here is a typical underwriting checklist.

Practical Scope of Underwriting Review

Part I — Commercial Reality & Structural Credibility

Underwriting begins with structural credibility. Before reviewing financials or projections, the acquirer evaluates whether your business operates like a genuine commercial enterprise. The goal at this stage is coherence: does your website, product presentation, pricing logic, and operational structure behave like a real trading business?

This section outlines the practical elements that commonly fall within scope when assessing whether a merchant’s offering is substantively real. Not all items will apply to every business model, but serious operators should expect that any of these areas may be reviewed.

Physical Goods & Presentation Checklist

  • Detailed, accurate product descriptions (materials, dimensions, specifications)
  • Multiple authentic product images per SKU
  • Functional variant selectors (size, colour, configuration)
  • SKU differentiation across products
  • Clear pricing displayed with currency
  • Clear tax/VAT treatment
  • Realistic shipping timelines by geography
  • Defined shipping cost logic
  • Clear stock selection functionality
  • Sample customer invoice or receipt format
  • No placeholder text or broken purchase flows
  • Localisation consistent with target market (currency, sizing, measurement units)
  • Country dropdown restricted to serviceable locations

Part I-A — Supply Chain & Product Sourcing

After confirming frontend credibility, underwriting examines backend sourcing. The core question is whether the merchant can trace goods or services back to legitimate commercial relationships. Assertions alone are insufficient; documentation is often required.

This is particularly important for branded goods, regulated goods, and digital reselling models. Merchants should be prepared to evidence commercial engagement, not merely describe it.

Supply Chain Checklist

  • Supplier or manufacturer agreements
  • Distributor or reseller agreements
  • Licensing agreements (where applicable)
  • Brand authorisation letters (if selling branded goods)
  • 3–6 recent supplier invoices
  • Matching bank statements showing payment of those invoices
  • Dropshipping contracts (if applicable)
  • Description of product authenticity controls
  • Explanation of IP ownership (for digital goods)
  • Evidence of exclusive or non-exclusive rights (if applicable)

Part I-B — Logistics, Fulfilment & Returns

Physical commerce introduces operational risk at the fulfilment stage. Underwriting evaluates whether the merchant has structured systems to manage delivery, returns, and disputes. Chargeback risk frequently correlates with poor logistics control rather than fraud.

This section covers operational mechanics that may be reviewed during underwriting or ongoing monitoring.

Logistics & Returns Checklist

  • Warehouse location details
  • Inventory management system explanation
  • Stock tracking and restocking procedures
  • Courier or shipper agreements
  • Recent courier invoices
  • Delivery tracking procedures
  • Proof-of-delivery retention policy
  • Signature requirement policy (if applicable)
  • Lost shipment handling procedure
  • Non-delivery dispute process
  • Return authorisation workflow
  • Refund processing timeline
  • Escalation policy for customer complaints
  • Policy on damaged or faulty goods

Part II — Business Maturity: Established vs Early Stage

Underwriting differentiates sharply between established and early-stage businesses. Established merchants are evaluated through historical financial and processing reconciliation. Early-stage businesses are evaluated through preparation, structure, and capital commitment.

The documentation expectations below reflect both categories.

Established Business Checklist

  • 3–6 months processing statements
  • Corresponding bank settlement statements
  • 1–2 years filed financial statements
  • Latest management accounts (if recent financial year not yet filed)
  • Refund reports (last 6–12 months)
  • Chargeback reports (last 6–12 months)
  • Fraud monitoring reports (if available)
  • Monthly revenue breakdown
  • Geographic revenue breakdown
  • Supplier invoices aligned with volume
  • Matching supplier payments in bank statements
  • Explanation of any unusual transaction spikes
  • Description of seasonality effects (if applicable)
  • Customer invoice format
  • Evidence of tax filings (if applicable)

Early-Stage Business Checklist

  • Formal business plan
  • Defined product/service description
  • Target market description
  • Competitive positioning analysis
  • 12-month cashflow projection
  • Marketing budget allocation
  • Capital injection evidence
  • Founder CVs or LinkedIn profiles
  • Organisational structure overview
  • Defined go-to-market strategy
  • Ad account setup evidence
  • Partnership or affiliate strategy (if applicable)

Part III — Customer Acquisition & Advertising

Revenue must be traceable to identifiable acquisition pathways. Underwriting will examine how customers are generated and whether acquisition strategy aligns with reported or projected scale.

Merchants should expect to explain not just volume, but origin.

Acquisition & Marketing Checklist

  • Description of primary acquisition channels
  • Paid advertising accounts (Google, Meta, TikTok, etc.)
  • Ad spend summaries (if established)
  • Affiliate agreements
  • Influencer or partnership contracts
  • Sample advertising creatives
  • Geographic targeting explanation
  • Cost-of-acquisition estimates
  • Funnel description (from click to checkout)
  • Analytics setup confirmation
  • Google Analytics or equivalent access (if requested)

Part IV — Public Claims & Reputation

Public-facing claims may be reviewed for proportionality and accuracy. Underwriting does not rely solely on marketing statements but may verify them against observable footprint.

Claims about customer volume or satisfaction should be defensible.

Reputation & Public Claims Checklist

  • Links to review platforms (Trustpilot, Google, etc.)
  • Explanation of “customers served” figures
  • Social media account links
  • Engagement metrics (if referenced)
  • Clarification of rating claims
  • Description of customer service processes
  • Response time metrics (if available)
  • Public complaint handling procedure

Part V — KYC, AML & Legal Structure

Regulatory onboarding is mandatory and independent of commercial review. Directors and beneficial owners must satisfy KYC and AML requirements. Corporate structures must be transparent and fully disclosed.

Incomplete or inconsistent documentation at this stage creates friction regardless of business strength.

KYC & Corporate Documentation Checklist

  • Government-issued ID for all directors and UBOs
  • Proof of address (recent utility bill or bank statement)
  • Certificate of incorporation
  • Articles of association
  • Shareholding or ownership structure chart
  • Register of directors and shareholders
  • Organisational structure overview
  • Sanctions declarations (if required)
  • Beneficial ownership disclosure
  • Certificate of good standing (if applicable)

Part V-A — Website & Card Scheme Compliance Requirements

Beyond corporate documentation, your website must meet scheme and compliance standards. These requirements are not cosmetic; they are mandatory under card scheme rules and acquirer policies.

Merchants should treat website compliance as part of risk management, not merely presentation.

Website & Scheme Compliance Checklist

  • Website uses HTTPS (SSL certificate active)
  • Website does not redirect to unapproved domains during checkout
  • Product descriptions are clear and accurate
  • Product pricing and currency are plainly presented
  • Website footer contains links to:
    • Terms & Conditions
    • Privacy Policy
    • Refund Policy
    • Shipping Policy (if applicable)
  • Terms & Conditions clearly identify:
    • Merchant legal entity name
    • Registration number
    • Registered address
    • Registered country or territory
    • Contact information
    • Legal jurisdiction governing the agreement
    • Legal jurisdiction for dispute resolution
  • Terms clearly describe:
    • Shipping policy
    • Returns policy
    • Refund policy
    • Dispute resolution procedure
  • Website footer displays:
    • Merchant legal name
    • Registered address
    • Registered country/territory
    • Company registration number
  • Website footer displays:
    • Customer support email address
    • Customer support phone number (if available)
  • Website footer displays accepted card scheme logos
  • Checkout page clearly lists:
    • Product name
    • Quantity
    • Individual price
    • Currency
  • Checkout clearly lists:
    • Total amount to be charged
    • Taxes included (if applicable)
  • PCI compliance confirmation (self-attestation or SAQ as required)

Part VI — Ongoing Monitoring & Change Management

Approval does not conclude underwriting scrutiny. Acquirers monitor merchants continuously and may reassess risk exposure if material changes occur. Merchants are expected to disclose significant changes proactively rather than after implementation.

Treat ongoing compliance as part of operational governance.

Ongoing Oversight Checklist

  • Advance notification of new product categories
  • Disclosure of subscription or trial introduction
  • Geographic expansion notice
  • Changes to fulfilment providers
  • Significant pricing model changes
  • Updated Terms & Conditions reflecting changes
  • Explanation of sudden volume increases
  • Fraud or dispute spike reporting procedure
  • Internal compliance contact designation

Updated 1 day ago