The Green Sheet Online Edition
December 22, 2025 • 25:12:02
Mastercard Alert to Control High Risk Merchants (MATCH) Pro
Credit bureaus have less relevance than they did in the past. Buy now, pay later and peer to peer lending are not fully illustrated, medical collections are no longer shared, and rent payments are not captured. Consequently, acquirers and processors are more often relying on banking information and real-time transactional data, which is more timely for their underwriting decisions.
MATCH continues to be a data point in assessing a merchant's risk, but it, too, has changed to better assist underwriters. These changes are significant. Both merchants and payment professionals need to be aware of how MATCH has transformed to MATCH Pro and how to properly integrate those changes into their processes.
The new name, MATCH Pro, will likely not stick; payment professionals will continue to call it MATCH. Mastercard renamed it to differentiate how these new rules will be applied going forward and is also deprecating its legacy APIs.
Regardless, adherence to the MATCH rules remains mandatory. Acquirers must inquire into MATCH before approving a merchant, and, if the conditions exist at the time of termination, the merchant must be added to MATCH.
A risk tool
MATCH remains a risk tool, not a blacklist. Acquirers are provided possible MATCH alerts. They must determine if the MATCH is a false positive or a true MATCH and, if it is a true MATCH, whether to board the merchant.
Many acquirers, however, will not approve a MATCH merchant, regardless of the reason for the merchant's MATCH designation. Consequently, with the limited number of acquirers, MATCHed merchants pay a much higher rate for processing, that is, if they are able to accept card payments.
To assist merchants with disputing their MATCH designation, the MATCH rules now require acquirers to respond to merchant inquiries within 30 calendar days. This is an essential and overdue rule, given that acquirers previously had no obligation to respond to merchants' MATCH dispute claims. This frustration was compounded by the rise of payfacs, many of which routinely ignored MATCH-related merchant inquiries.
The acquirer that added the merchant must now provide the ICA number and the reason code to the merchant or to another acquirer. Additionally, although not newly introduced, it is worth reiterating that if the MATCH conditions exist at the time the merchant closed, the acquirer must add the merchant to MATCH regardless of whether the closure was voluntarily requested by the merchant.
The MATCH addition must take place within five calendar days of:
- the acquirer's decision to terminate the merchant,
- the merchant's request to terminate the relationship, or
- the acquirer becoming aware of an issue that meets a MATCH reason code.
Retroactive MATCHes continue and will persist for 365 days from the inquiry date for merchants added by a subsequent acquirer. MATCHed merchants are maintained for five years, and there are extremely limited reasons for removal once a merchant is added. Outside of remediating PCI compliance, the typical and singular reason for MATCH removal is in the event the merchant was added in error.
The MATCH reason codes are as follows:
- 01 Account data compromise
- 03 Transaction laundering
- 04 Excessive chargebacks
- 05 Excessive fraud
- 06 Coercion
- 08 Mastercard Questionable Merchant audit program
- 09 Liquidation/insolvency
- 10 Violation of Standards
- 12 PCI Data Security Standard noncompliance
- 13 Illegal transactions
- 14 Identity theft
Clarified chargeback standards
A significant change in MATCH Pro concerns Reason Code 04, Excessive chargebacks. Mastercard now expressly defines the timeframe as "over the previous three months," eliminating the ambiguity that previously led to inconsistent interpretations.
Under the clarified standard, a merchant must exceed a 1.5 percent chargeback ratio and have at least $5,000 in Mastercard chargebacks within that period.
These explicit thresholds resolve long-standing confusion and establish a uniform basis for applying RC-04.
While removal is still rare, MATCH Pro's clarified standards are creating more opportunities for legitimate corrections. In practice, several common categories of erroneous MATCH listings have emerged.
In speaking with Eugene Rome and Brad Cebeci of Rome LLP, who routinely handle MATCH disputes, I learned of several recent cases—anonymized but representative of current industry patterns—that illustrate the scenarios in which they have successfully secured MATCH removals. The cases are:
- When an acquirer acknowledges internal error: A processor mistakenly froze two active MIDs due to
misidentified "unauthorized" transactions, later admitting the error. The accounts were restored, but MATCH listings remained. Once the disconnect was documented, the acquirer withdrew both RC-04 entries.
- When a merchant relied on acquirer-approved processing practices: A merchant MATCH-listed for descriptor violations was later cleared after evidence showed the ISO and gateway had promoted, approved and enabled the exact descriptor settings used.
- When RC-04 metrics don't satisfy Mastercard thresholds: A merchant MATCH-listed for "Excessive Chargebacks" was below Mastercard's required levels. Once objective chargeback data was provided, the listing was removed.
- When reputational shutdowns are mislabeled as fraud: A high-visibility merchant facing public controversy was MATCH-listed for "fraud" even though no fraud, laundering or illegal activity was present. The acquirer ultimately withdrew the listing after acknowledging the termination was strictly reputational.
MATCH use still mandatory
MATCH Pro doesn't change the obligation to use MATCH, but it does raise the bar for accuracy, response timelines and reason-code clarity. For the industry, this means:
- Better submissions;
- Faster dispute resolution;
- More predictable underwriting outcomes; and
- Fewer erroneous MATCH listings that damage merchant viability.
For acquirers and ISOs, the priority going forward is to ensure internal policies align with Mastercard's clarified rules (especially RC-04) and to prepare for a rise in data-driven challenges to MATCH listings that don't hold up under MATCH Pro scrutiny.
Merchants should do all in their power to remain off MATCH. Acquirers should leverage MATCH in conjunction with their broader underwriting and risk-mitigation processes to adjudicate merchants and maintain awareness of merchant risk.
As founder of Humboldt Merchant Services, co-founder of Eureka Payments, and a former executive for such payments innovators as WePay, a division of JPMorgan Chase, Ken Musante has experience in all aspects of successful ISO building. He currently provides consulting services and expert witness testimony as founder of Napa Payments and Consulting, www.napapaymentsandconsulting.com. Contact him at kenm@napapaymentsandconsulting.com, 707-601-7656 or www.linkedin.com/in/ken-musante-us.
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