Special conditions for subscriptions and tokenized payments

In this article you can find have revised requirements for merchants that use recurring charges on a stored card (e.g. monthly membership fees or streaming services).

These requirements will help ensure a more positive cardholder experience and mitigate negative practices associated with the utilization of a subscription/recurring billing model. The new requirements are consistent with the European Union’s consumer protection regulations.

If you offer customers a service that involves subscription/recurring billing, please note the following instructions:

  • You must clearly disclose the basic terms of the subscription/recurring billing at the point of payment and capture the customer’s acceptance of such terms (e.g. ticking a box). The disclosure must include the amount that will be billed and the frequency of the billing.
  • Providing a link to another page that contains this information (such as a terms and conditions page), or otherwise requiring the customer to expand a message box or scroll down the page to see the terms, will not satisfy the above requirement.
  • A confirmation email must be sent to the customer at the time of enrollment in a subscription/recurring billing plan that provides the terms of the subscription, including the terms of a trial period when applicable, and clear instructions about how to cancel the subscription.
  • If a trial period (either free or discounted) is offered which thereafter recurring payments will be charged, you must disclose to the customer:the terms of the trial, including any initial charges, the length of the trial period, and the amount and frequency of the subsequent subscription.
    • For example: You will be billed 4,99€ today for a 14-day trial. Once the trial ends, you will be billed 39,99€ each month thereafter until you cancel.
  • Before the end of the trial period, a reminder notification must be sent to the customer no less than three days, and no more than seven days, that the subscription plan will begin if the customer does not cancel.
    • This notification must include the basic terms of the subscription and instructions about how to cancel.
    • This reminder can be completed by email message or any other electronic method.
  • For any subscription/recurring payment plan that bills a cardholder less frequently than every six months, a notification must be sent at least seven days, but no more than 30 days, before the billing date that includes the terms of the subscription and instructions about how a cardholder may cancel the subscription.

Please note that it is recommended to follow Paytrail's documentation when implementing recurring payments. The new requirements come into effect from 22.09.2022. If the requirements are not met, the card company has the right to chargeback a payment from the merchant when there is a payment dispute from a customer.


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