This information applies to both Financial Accounts for platforms and Issuing integrations. To offer and promote Financial Accounts for platforms and Issuing products to your customers and connected accounts, your marketing and user interfaces must adhere to the guidelines that we outline here. These guidelines help you navigate the financial regulations that apply to Stripe products. We’ve organized them into the following sections:

• Account management
• Required agreements and disclosures for Issuing
• Required agreements and disclosures for Financial Accounts for platforms
• Required agreements and disclosures for fees, credits, and rewards programs
• Customer communications and documents
• Going live and marketing
• Recordkeeping

The following table outlines the steps you must complete before onboarding your first connected accounts. If you need help, contact the Stripe Compliance team at [email protected].

If you make changes to any items in the table at a later date, you must submit a request to the Stripe Compliance team using the Change Request Form.

Account management

Before you launch Financial Accounts for platforms or Issuing, you must implement the proper internal compliance controls. You also need to build the processes described in this section into your various workflows, customer service, and product channels.

Complaints program guidance

Complaints are any expression of dissatisfaction with a product, service, policy, or employee related to Financial Accounts for platforms or Issuing, except those expressions made by employees of your company. Properly handling complaints is mandatory when offering financial services products. See the Handling complaints guide for detailed complaint management requirements.

Disputes and charge errors

As part of providing customer support, you might be notified of suspected disputed charges, charge errors, or both. The two most common types of disputes or errors are:

• You or your customer believe a charge is unauthorized
• You or your customer see an error on an account statement

If these errors occur, submit the dispute through the Stripe Dashboard. Select the relevant transactions and choose Dispute. Be prepared to provide Stripe with specific information to investigate the dispute, such as:

• Details about the authorized user
• Details about the disputed charge amount
• The transaction date
• An explanation of why the disputed charge is an error or unauthorized

You must report any disputed charge or error immediately upon notification of it. Failure to do so might impact your financial liability. To avoid a sustained reduction to your available balance, you can pay the disputed charge while we determine the validity of the dispute. If Stripe deems the dispute valid, we credit the disputed charge amount back to the appropriate account.

Application flow

Your platform must provide for three main compliance requirement workflows:

• Collection of required KYC information
• Presentation of the required bank disclosure
• Ensuring that your applicant reads and accepts the required legal agreements

Required agreements and disclosures for Issuing

If you’re a platform and you’re not using Stripe-hosted onboarding, you must:

• Present the following program-specific agreements and disclosures for your connected accounts to accept when they open their account.
• Provide connected accounts with ongoing access to these agreements.
• Present each agreement separately. You can’t combine them into one agreement for your cardholders to accept.

Connected Account Agreements and Disclosures.

You must provide the following agreements to your connected accounts before they can start using the Issuing Spend Card Program:

• Stripe Connected Account Agreement
• Stripe Issuing Accountholder Terms
• Issuing Bank Terms
  • Celtic Bank Users only: Issuing Bank Terms - Spend Card (Celtic Bank)
  • Cross River Bank Users only: Issuing Bank Terms - Spend Card (Cross River Bank)
• Apple Pay Terms (if enabled for your program)
  • Apple Pay Accountholder Terms

In addition to the above agreements, you must provide the following disclosures to your connected accounts before they can start using the Issuing Spend Card Program:

• Electronic Signature Consent: You must include text near the “Issuing Bank Terms” link that states: “By clicking “submit application,” you agree to the Issuing Bank Terms, Stripe Connected Account Agreement, and Stripe Issuing Accountholder Terms, and you consent to electronic signatures as set forth in the Issuing Bank Terms.”
• Commercial Financing Disclosure: For Connected Accounts with a business address in NY or UT, you must present one of the following disclosures:
  • For platforms that don’t charge fees:
    • Celtic Bank Users only: Commercial Financing Disclosure (Celtic Bank) (no fee)
    • Cross River Bank Users only: Commercial Financing Disclosure (Cross River Bank) (no fee)
  • For platforms that charge a $0.10 fee when creating cards for users:
    • Celtic Bank Users only: Commercial Financing Disclosure (Celtic Bank) (fee included)
    • Cross River Bank Users only: Commercial Financing Disclosure (Cross River Bank) (fee included)
  • For platforms that charge fees other than a $0.10 fee when creating cards for users:
    • If you charge fees beyond Stripe’s fee of 0.10 USD, you might be required to create your own commercial financing disclosure to present to your connected accounts for creating virtual cards. You must report custom fees through Stripe’s Change Request Form, and you must submit custom commercial financing disclosures to [email protected]. Both the custom fee and custom disclosure are subject to Stripe’s review and approval. To assess the applicability of commercial financing disclosures to your program, contact [email protected].

Authorized User Agreements and Disclosures.

If you or your connected accounts create an individual type Cardholder, also known as an “authorized user,” you must present to cardholders—typically during the card activation process—the following agreements:

• Stripe E-Sign Disclosure
• Authorized User Terms
  • Celtic Bank Users only: Authorized User Terms (Celtic Bank)
  • Cross River Bank Users only: Authorized User Terms (Cross River Bank)
  • Fifth Third Bank Users only: Authorized User Terms (Fifth Third Bank)

Charge card users

Connected Account Agreements and Disclosures.

You must provide the following agreements to your connected accounts before they can start using the Issuing Charge Card Program:

• Stripe Connected Account Agreement
• Stripe Issuing Accountholder Terms or Custom Platform Accountholder Terms
• Issuing Bank Terms
  • Celtic Bank Users only: Issuing Bank Terms - Charge Card (Celtic Bank)
  • Cross River Bank Users only: Issuing Bank Terms - Charge Card (Cross River Bank)
  • Fifth Third Bank Users only: Issuing Bank Terms - Charge Card (Fifth Third Bank)
• Apple Pay Terms (if enabled for your program)
  • Apple Pay Accountholder Terms
• Card Program Terms: These are your bespoke program terms that supplement the Issuing Bank Terms. At a minimum, consider including the following items in your terms. Consult your legal counsel about which items to define within your own Card Program Terms.
  • Repayment methods, including automatic withdrawal consents
  • Billing cycles, including due dates
  • Fees
  • Rewards
  • Credit limits
  • Account closure requirements

In addition to the above agreements, you must provide the following disclosures to your connected accounts before they can start using the Issuing Spend Card Program:

• Electronic Signature Consent: You must include text near the Issuing Bank Terms link stating that signing the Issuing Bank Terms signifies consent to electronic signatures and communications. For example, your message might read: “By clicking the submit application button, you agree to the Issuing Bank Terms, Stripe Connected Account Agreement, and Stripe Issuing Accountholder Terms; and you consent to electronic signatures as set forth in the Issuing Bank Terms.”
• Commercial Financing Disclosure: For connected accounts with a business address in NY or UT, you must present your own custom commercial financing disclosure. You must report custom fees through Stripe’s Change Request Form, and you must submit custom commercial financing disclosures to [email protected]. Both the custom fee and custom disclosure are subject to Stripe’s review and approval. Contact [email protected] to assess the commercial financing disclosure requirements of your program.

In the context of authorized user agreements and disclosures, if you or your connected accounts create an individual type Cardholder, also known as an “authorized user,” you must present to cardholders—typically during the card activation process—the following agreements:

• Stripe E-Sign Disclosure
• Authorized User Terms
  • Celtic Bank Users only: Authorized User Terms (Celtic Bank)
  • Cross River Bank Users only: Authorized User Terms (Cross River Bank)
  • Fifth Third Bank Users only: Authorized User Terms (Fifth Third Bank)

Commercial prepaid debit users

You must provide the following agreements to your connected accounts before they can start using your Issuing Commercial Prepaid Debit Card Program:

• Stripe Connected Account Agreement
• Stripe Issuing Accountholder Terms
• Issuing Bank Terms
  • Sutton Bank users only: Issuing Bank Terms - Payout Card (Sutton Bank)
  • Cross River Bank users only: Issuing Bank Terms - Commercial Prepaid Card (Cross River Bank)

In the context of authorized user agreements and disclosures, if you or your connected accounts create an individual type Cardholder, also known as an “authorized user,” you must present to cardholders—typically during the card activation process—the following agreements:

• Stripe E-Sign Disclosure
• Authorized User Terms
  • Sutton Bank users only: Sutton Bank Authorized User Terms
  • Cross River Bank users only: Cross River Bank Authorized User Terms

Required agreements and disclosures for Financial Accounts for platforms

You must provide the following terms of service to your connected accounts and record their agreement before they can start using your Financial Accounts for platforms Program:

• Stripe Services Agreement
• Financial Accounts for platforms Terms - Connected Accounts

Required agreements and disclosures for fees, credits, and rewards programs

In addition to the previous agreements, your terms of service and fee schedule must clearly outline the fees and terms that you implement as part of your Financial Accounts for platforms or Issuing program.

You must report to Stripe the details of any fees, credits, and rewards programs that you plan to offer. That helps make sure your user interfaces and marketing materials are compliant with financial regulations regarding fees or offer credits, especially in the form of rewards programs. Use the Change Request Form.

Customer communications and documents

To comply with applicable laws and regulations, you must send certain communications to both your applicants and accountholders upon certain trigger events.

To learn about customer communication requirements when using Issuing and Financial Accounts for platforms together, see Issuing regulated customer notices.

Statements

Providing statements, while optional, is a best practice that allows your Financial Accounts for platforms or Issuing customers to periodically check their transaction history. If you send statements, make sure they contain the following information:

• [Company] name and address.
• Your company’s customer support contact number and website
• Customer account number
• Customer name and address
• Required disclosures
• Transaction history (including opening and closing balances for the statement period)
• Fees and credits.
• Information about how you resolve errors and complaints

Receipts

One of the most important ongoing obligations you have in overseeing your Financial Accounts for platforms or Issuing program is providing your customers with money transmissions receipts. Every regulated transaction your customers initiate generates a compliant money transmission receipt URL that you must share with your customer. You can provide these URL receipts in a few different ways, such as emailing them or making them available in your customer’s Dashboard. See the