Blacklisted: MATCH, and Why the TMF Is Not the Same Thing
- MATCH is a shared database of terminated merchants. Records stay for 5 years; a listing makes finding a new acquirer harder, but isn't a ban
- Termination puts you there, not your ratio. A reason code applying at termination makes listing mandatory within five calendar days. Nobody has to warn you first
- Mastercard publishes the numbers. Code 04 is chargebacks over the previous three months above 1.5% of your Mastercard sales, plus USD 5,000 or more in chargebacks. Both, not either
- Code 05 is an 8% fraud-to-sales ratio over the previous three months, plus 10 or more fraudulent transactions of USD 5,000 or more. That's far above the fraud rate your processor chases you about
- Being listed isn't a ban. Mastercard says twice that an acquirer may still board you. Most won't, but that's appetite, not a rule
- You can ask to come off. Mastercard states in writing that you don't need a lawyer
A rising ratio doesn't automatically put you on MATCH. Check your processor's written limits and reply to any warning. Don't assume a warning has to come first; termination with a qualifying reason code is what matters.
What Is MATCH?
Mastercard runs the database. It's MATCH, the Mastercard Alert To Control High-risk Merchants. The current rules brand it MATCH Pro.
Visa's TMF (Terminated Merchant File) isn't just a private file. Rule 10.10.1.1 covers records your acquirer retains and reporting to a common terminated-merchant database. Rule 10.10.1.2 adds region-specific database duties. Visa's VMSS, the Visa Merchant Screening Service, has separate participation rules in section 10.17.
The listing clocks differ too. Visa's rule 10.10.1.1 requires reporting by close of business the day after notice of intent to terminate, where that rule applies. Mastercard gives the acquirer five calendar days under section 11.5. Ask which database and regional rule your notice names. NETWORK Visa's public rules, 18 April 2026, checked 22 October 2026.
Your processor adds you to MATCH for certain terminations. Every acquiring bank checks it before onboarding a new merchant. If you're on it, most legitimate processors won't touch you.
Think of it as the credit report for merchants. Except there's no score, just a scarlet letter.
The 11 MATCH Reason Codes
Your processor must specify why they're adding you. Each reason code tells future processors what happened.
| Code | Reason | Duration | How Common |
|---|---|---|---|
| 01 | Account Data Compromise | 5 years | Rare |
| 03 | Transaction Laundering | 5 years | Rare |
| 04 | Excessive Chargebacks | 5 years | Very Common |
| 05 | Excessive Fraud | 5 years | Common |
| 06 | Coercion | 5 years | Rare |
| 08 | Mastercard Questionable Merchant Audit Program | 5 years | Rare |
| 09 | Liquidation/Insolvency | 5 years | Uncommon |
| 10 | Violation of Standards | 5 years | Uncommon |
| 12 | PCI Data Security Standard Noncompliance | 5 years (early removal possible with PCI certification) | Uncommon |
| 13 | Illegal Transactions | 5 years | Rare |
| 14 | Identity Theft | 5 years | Rare |
Source: Mastercard, Security Rules and Procedures - Merchant Edition, 4 August 2026, section 11.14.1, Table 11.4, p.157.
Most of the internet still publishes the old fourteen.
Codes 02, 07 and 11 no longer exist. Common Point of Purchase folded into code 01 instead. That definition now ends "(i.e., Common Point of Purchase [CPP])". Fraud Conviction and Merchant Collusion were deleted outright.
Code 06 was "Reserved for Future Use" through the 6 August 2024 edition. It's Coercion now.
Code 03 is Transaction Laundering, not "Laundering". Its definition now ties to the merchant agreement. Code 09 dropped "Bankruptcy" and is just Liquidation/Insolvency. Code 08 is spelled out rather than abbreviated to QMAP.
The change landed in the 11 February 2025 edition. The 4 August 2026 one keeps it. If a page shows you 14 codes, it's quoting a dead rulebook.
Mastercard also adds listings itself. It uses codes you won't find in Table 11.4. Chapter 8 has 00 Questionable Merchant/Under Investigation, 20 Mastercard Questionable Merchant Audit Program, and 24 Illegal Transactions. You can sit under code 00 during an investigation. No termination, and no acquirer decision behind it.
For most SMBs, codes 04 and 05 are the threat. Excessive chargebacks and excessive fraud put small businesses on MATCH.
What Triggers MATCH Listing
Termination triggers it. Not the ratio.
Section 11.5 (p.151) is blunt about this. Say either side moves to end the acquiring relationship. A Table 11.4 condition applies at that moment, or the acquirer has reason to believe one does. Then the acquirer must add you to MATCH Pro within five calendar days. The ratio is the gate. Walking out the door opens it.
That cuts both ways. Section 11.4, item 8 is the half nobody ever quotes. A reason code "must be met or suspected (at decision to terminate) to justify a MATCH Merchant addition". Acquirers who use or threaten MATCH "as a collection tool for minor MATCH Merchant discretionary activity may be subject to a noncompliance assessment". So an acquirer who terminates you at 0.95% can't lawfully list you under code 04. You're under the floor. Item 9 of the same list runs the other way. Fail to list a merchant who does qualify, same assessment.
It's mandatory both ways. Your processor doesn't get to decide.
Reason Code 04, Excessive Chargebacks
Mastercard publishes this one in full. Table 11.4, verbatim:
With respect to a MATCH Merchant reported by a Mastercard Acquirer, the aggregate number of Mastercard chargebacks over the previous three months exceeded 1.5% of its Mastercard sales Transactions in that month, and those chargebacks equaled or exceeded USD 5,000 in total.
Two conditions, not one. 1.5% and USD 5,000. A small merchant can sit well above the percentage for months. They may still never clear the dollar floor.
The denominator is Mastercard only. Not your total card volume, not Visa, not Amex. Say Mastercard is a quarter of your sales. You can be far over 1.5% there while the blended dashboard looks calm. Table 11.4 draws no line between credit, debit, prepaid, card-present or card-not-present. Mastercard chargebacks over Mastercard sales, full stop.
One carve-out worth knowing: American Express acquirers report under ICA 102 through 125. For them, code 04 reads "exceeded the chargeback thresholds of American Express, as determined by American Express". No number. Entirely their call. The published 1.5% covers Mastercard-acquired merchants and nobody else.
Before February 2025 the test read differently: 1% in any single month, plus USD 5,000. Terminated before then, you were judged on the old single-month rule.
Read code 04 again, exactly as printed. "The aggregate number of Mastercard chargebacks over the previous three months exceeded 1.5% of its Mastercard sales Transactions in that month."
Three months of chargebacks. Divided by one month of sales. Nobody can compute that.
It happened in the February 2025 rewrite. The old text read "in any single month exceeded 1% of the number of Mastercard sales Transactions in that month". Someone stretched the numerator out to three months. "In that month" stayed in the denominator. Code 05 carries the same scar. "Fraud-to-sales dollar volume ratio was 8% or greater than the previous three months" isn't a sentence. The 4 August 2026 edition still carries this wording.
So here's the honest answer, the one no vendor hands you. The number is published: 1.5%, USD 5,000, three-month lookback. The formula isn't. Read literally, code 04 is arithmetically incoherent. Read charitably, it's three months over three months. That charity is ours, not Mastercard's. Got a clean code 04 calculator from a vendor? Ask which denominator it used. It picked one. Mastercard didn't.
When a processor might terminate
Mastercard's number says when a listing is permitted. It says nothing about when your processor decides to terminate. Termination is the event that starts all of this.
| Scenario | What to check |
|---|---|
| One month's ratio rises | Compare it with your processor's limit |
| The ratio keeps rising | Ask for a remediation plan and deadline |
| A limit is breached | Confirm whether termination is under consideration |
| No improvement after remediation | Send results and agree the next step |
| A processor warning arrives | Reply by the deadline in the notice |
A ratio alone doesn't predict termination. It doesn't make you listable either: code 04 needs more than 1.5% on Mastercard volume with USD 5,000 in chargebacks behind it. Get your processor's requirements in writing; see Monitoring Thresholds.
Processors can act before a MATCH condition applies. Reply to warnings, carry out the agreed remediation plan, and ask which listing condition they believe exists. Effort doesn't waive a listing duty when the conditions apply.
Reason Code 05, Excessive Fraud
This one's published too. The number is nothing like what merchants are told to fear. Table 11.4, verbatim:
The MATCH Merchant effected fraudulent Transactions of any type (counterfeit or otherwise) meeting or exceeding the following minimum reporting Standard: the MATCH Merchant's fraud-to-sales dollar volume ratio was 8% or greater than the previous three months, and the MATCH Merchant effected 10 or more fraudulent Transactions equal to or greater than USD 5,000 in the previous three months.
8%. Three conditions stacked: the ratio, 10 or more fraudulent transactions, and USD 5,000.
MATCH code 05 has its own test. Don't substitute a chargeback ratio or a processor's warning limit for it. Check VAMP and ECM separately, and ask your processor which metric its warning uses.
Other Common Triggers
PayFac terminations: A PayFac can list you the same way. Stripe, Square and PayPal can all do it when they terminate your account. Ask which reason code applies and get their termination terms in writing.
Code 10 (Violation of Standards): Selling prohibited products, misrepresenting your business, processing for someone else. Code 10 carries no number at all. That's exactly why an acquirer reaches for it. Being under the 1.5% floor stops code 04. It doesn't stop code 10.
How Long You Stay on MATCH
Five years, and Mastercard publishes that too. Section 11.10, p.155:
MATCH Merchant records remain on the MATCH Pro system for five years, at which point they are automatically purged from the MATCH Pro system.
Searches look back five years (11.6.1). Inquiry records are kept 365 days.
| Reason Code | Duration | Early Removal Possible? |
|---|---|---|
| 01, 03-06, 08-10, 13-14 | 5 years | Yes, by request through the acquirer that listed you |
| 12 (PCI) | 5 years | Yes, on achieving PCI compliance certification |
You can ask to come off, and you don't need a lawyer
Mastercard's own rules say so. Section 11.5.1, p.151:
Any MATCH Merchant may contact an Acquirer regarding a request to be removed from MATCH Pro. For the avoidance of doubt, there is no requirement for a MATCH Merchant to engage legal counsel regarding a request to be removed from MATCH Pro.
Mastercard wrote that second sentence on purpose. Consider who benefits from it staying obscure.
The request needs four things:
- Current and/or previous merchant name
- Current and/or previous merchant address
- Principal owner's first and last name
- Merchant website URL, if you have one
That's a letter, not a retainer.
What your acquirer owes you:
| Obligation | Deadline | Rule |
|---|---|---|
| Respond to a removal request | 30 calendar days | 11.4, item 1 |
| Answer your questions about the listing | 7 calendar days | 11.4, item 2 |
| Give you the listing ICA and the reason code | On request | 11.4, item 10 |
Mastercard removes a listing when the acquirer reports it was added in error (11.13). For code 12, PCI noncompliance, you can go direct to Mastercard. Email MATCHPro.help@mastercard.com if your acquirer won't file.
In the EEA or California you have a second lever. Appendix F.5 (p.227) confirms that GDPR rights apply to MATCH data. Access, rectification, erasure, portability, restriction and objection. CCPA rights to know, correct and delete come with it. Mastercard puts the work on your acquirer. They're "responsible for addressing the requests regarding the rectification or correction and erasure or deletion of Personal Information".
None of this makes removal easy. Your acquirer still has to agree it was an error. Most of the time they won't. But "no appeal, hire a lawyer" isn't what the rulebook says.
What Happens After MATCH Listing
Immediate Effects
- Check which accounts were closed. A listing doesn't itself close every other account.
- Ask about held reserves. Use the release conditions in your notice, not a guessed six-month term.
- Check pending payouts separately. Get the amount, deductions and next review or release date in writing.
Finding a New Processor
Before applying, check whether the provider's policy covers your actual product, channel and countries.
Mastercard says this twice, in section 11.2 (p.148) and again in 11.6.4. Lawyers write like this when they're tired of being misquoted: "For the avoidance of doubt, an Acquirer may onboard a Merchant (and a Payment Facilitator may onboard a Sponsored Merchant) listed in MATCH Pro."
The rule permits your rescue. The market usually declines it. Those are different sentences. Every page calling MATCH a five-year death sentence is describing acquirer appetite dressed up as a rule. Below is appetite.
You have three options:
| Option | Reality |
|---|---|
| Legitimate processors | Will almost always decline you. They all check MATCH, and a listing is a hard no at most underwriting desks. |
| High-risk specialists | Will consider you, at a price. |
| Cash only | Always available, but limits growth. |
High-Risk Processor Terms
If you go the high-risk route, get a written quote. The ranges below are labelled planning assumptions, not typical terms or published prices.
| Term | Planning assumption |
|---|---|
| Discount rate | 4-10% (vs. 2.5-3% for normal merchants) |
| Per-transaction fee | $0.25-0.50 (vs. $0.10-0.30) |
| Rolling reserve | Account-specific withholding and release terms; get them in writing |
| Monthly minimum | $25-50 |
| Chargeback fee | Get the amount, representment charges and refund policy in the quote |
| Setup fee | $0-500 |
Treat every row here as an illustrative planning assumption, not a quote or a market average. The mainstream comparison has a sourced US fee table. Ask each acquirer for its rate, fees, reserve schedule and release conditions before you sign.
Math check, assumed rates: $50,000/month x 2.9% = $1,450. At 7%, $50,000 x 7% = $3,500. That's $3,500 - $1,450 = $2,050/month extra, or $2,050 x 12 = $24,600/year. This compares percentage charges only; add fixed fees and reserve effects separately.
Avoiding MATCH
Monitor Before You're in Trouble
Set your own alarms before you reach the limits that apply to you:
| Metric | Where the line actually sits | Your internal threshold |
|---|---|---|
| Chargeback ratio | U.S. Visa VAMP merchant excessive is at least 1.5% and 1,500 combined fraud reports and disputes, when your acquirer isn't Above Standard or Excessive. Ask your processor for its own limit; see Network Programs for regional conditions | Leave time to investigate and fix the cause |
| Monthly dispute count | Mastercard ECM needs 100-299 disputes and a 1.50-2.99% ratio in the same month. Both, not either. HECM starts at 300 and 3.00% | Track the applicable count beside your ratio |
| Fraud ratio | Confirm your processor's definition and limit. MATCH code 05 is a separate test at 8% with count and dollar conditions | Set an alarm before the applicable limit |
MATCH is the exception here, and it's the good kind. Codes 04 and 05 are published in full. We quote them verbatim above, with a section and page number.
Visa publishes a public VAMP fact sheet. Mastercard's ECM and HECM numbers are relayed through acquirer documentation. See Network Programs for sources and conditions. Then ask your processor for the limits in your agreement. Those can differ from the network's.
When you hit your internal threshold, start remediation. Don't wait for processor warnings.
Respond Immediately to Processor Warnings
When your processor sends a warning email:
- Check it's real, then reply within 24 hours. Open your provider account or official support yourself, not the email's link (how). Silence looks like you don't care.
- Acknowledge the problem. Don't make excuses.
- Commit to a remediation plan. Be specific about actions and timelines.
- Ask what they need. "What would you need to see to be comfortable?"
Submit a Real Remediation Plan
Your plan should include:
| Element | What to Include |
|---|---|
| Root cause | Why chargebacks/fraud increased |
| Immediate actions | What you did in the first 48 hours |
| Short-term fixes | Changes this week (alerts, refund policy, etc.) |
| Long-term fixes | Systemic changes (product, process, policy) |
| Metrics commitment | "We expect to reach X% by [date]" |
| Reporting cadence | "We'll report weekly progress" |
Negotiate a Voluntary Exit
Termination's coming and you can't turn it around? Discuss an orderly wind-down, but don't treat it as protection from MATCH.
Ask: "Which MATCH reason code applies? Does this closure require a listing, and when does that duty start? Please confirm in writing."
Mastercard's section 11.5 covers termination initiated by either side when a listing condition exists. Good faith, a negotiated schedule and being only slightly over a threshold don't cancel that duty. NETWORK Mastercard's merchant rules, 4 August 2026, checked 22 October 2026.
If You're Already on MATCH
Step 1: Confirm the Listing
There's no self-service lookup. You can't query MATCH yourself.
You can make the acquirer who listed you hand it over. Section 11.4, item 10 requires the listing ICA and the reason code. Ask them in writing:
- "What reason code did you list us under?"
- "What is the listing ICA?"
- "What is the listing date?"
They owe you an answer within 7 calendar days. Processors declining you may confirm a listing exists, so ask. But the acquirer who listed you is the one on the hook.
Step 2: Contact the Listing Processor
Reach out to the processor who listed you:
- Request documentation of why you were listed
- Ask about reserve release timeline
- File a removal request if the listing is wrong (30 calendar days for their response, and no lawyer required)
Step 3: Evaluate Your Options
Step 4: If Using High-Risk Processor
- Read the contract carefully. High-risk processors have stricter terms.
- Understand reserve terms. When do you get your money?
- Get chargeback thresholds in writing. They may be lower than you had before.
- Budget for the extra cost. Price your products accordingly.
Step 5: Plan for Life After MATCH
In 5 years, you'll be off the list. Prepare:
- Maintain clean processing records with high-risk processor
- Document your remediation and performance
- Build relationships for when you can return to normal processing
When to Get a Lawyer
Not for a removal request. Mastercard says so in the rules (11.5.1). A lawyer adds cost to that letter without adding leverage.
Legal help makes sense when:
| Situation | Why Legal Help |
|---|---|
| Erroneous listing | You were listed incorrectly |
| Processor breach | They didn't follow their own policies |
| Reserve disputes | They won't release your money |
| Contract violations | Either party |
| Significant losses | Business damage from wrongful listing |
Cost reality: Ask for a written scope, hourly rate and estimate. Compare the likely legal cost with the amount at stake.
Test to Run
MATCH avoidance health check:
| Check | Action |
|---|---|
| Current ratio | Calculate today. How close are you to your processor's limit? |
| Trend | Compare last 3 months. Improving or worsening? |
| Processor relationship | When did you last communicate proactively? |
| Alert coverage | Do you have RDR/Ethoca/CDRN active? |
| Internal thresholds | Have you set warning thresholds below network limits? |
If you're approaching your processor's limit: Start the emergency remediation now, before it's a crisis.
Scale Callout
| Volume | MATCH Risk Profile |
|---|---|
| Under $50k/mo | Few transactions can make a small chargeback count look like a large ratio. Check the count and the code's conditions. |
| $50k-$500k/mo | Track your own counts, ratios and cash exposure. Volume alone doesn't establish the listing risk. |
| Over $500k/mo | Bring current results and a cash forecast to your acquirer. Don't assume volume buys a waiver or better reserve terms. |
| PayFac merchants | Ask your provider for its termination terms and warning process. |
Where This Breaks
-
PayFac terminations. Get your provider's warning and termination terms in writing. If you're having issues, reply to the notice and use the processor-warning steps.
-
Fraud you didn't cause. If you're a victim of a fraud attack, document everything. Ask your processor to note the circumstances if they must terminate.
-
Industry-wide issues. Some industries have structurally high chargeback rates (travel, supplements, subscriptions). Consider high-risk processors from the start.
-
Multiple MCCs. If you're processing under the wrong MCC code and get caught, that's a standards violation (code 10). Make sure your MCC matches your actual business.
Analyst Layer: Metrics to Track
Suggested internal reminders below are starting points. Tune them to your notice's deadlines and the person who'll act.
| Metric | What It Tells You | Action Threshold |
|---|---|---|
| Open processor warnings | Unresolved account requirements | Track the owner, deadline and written closure of each warning |
| Ratio trend (30/60/90 day) | Trajectory | Any upward trend = investigate |
| Distance to threshold | Risk buffer | Approaching your processor's limit = start remediation |
| Chargeback reason code distribution | Root cause | Shift in distribution = new problem |
| Reserve balance | Cash flow exposure | Track what's held and release dates |
Early Warning Dashboard
Track weekly:
Chargeback ratio: [___]% (processor's limit: [___]%)
Distance to threshold: [___] percentage points (internal alarm: [___])
Trend: [UP/DOWN/FLAT]
Chargebacks this month: [___] (applicable count limit: [___])
Alert coverage: [YES/NO]
Last processor contact: [___] days ago
Next Steps
Not on MATCH but worried?
- Calculate your current ratio → Chargeback Metrics
- Set up alerts → Setup Dispute Alerts Playbook
- Review your risk profile → Chargeback Ratio Crisis
Processor sending warnings?
- Respond immediately → Acknowledge and commit to action
- Build remediation plan → Use the template above
- Enable all deflection tools → Chargeback Alerts
Already on MATCH?
- Get the reason code and listing ICA → Ask the acquirer who listed you, they owe you both
- File a removal request if it's wrong → Four facts, 30-day response
- Explore high-risk options → Search "high risk merchant account [your industry]"
- Consider non-card alternatives → ACH, cash, invoicing
Sources
| Source | What it gave us | Kind | Date |
|---|---|---|---|
| Mastercard Security Rules and Procedures, Merchant Edition | The 11-code Table 11.4 (11.14.1, p.157), the verbatim code 04 and code 05 standards, the five-day listing duty (11.5), the removal process and the no-lawyer sentence (11.5.1), acquirer obligations (11.4), five-year retention (11.10), error removal and the code 12 route (11.13), "an Acquirer may onboard" (11.2 and 11.6.4), ECM/HECM deferral (8.3), Mastercard's own codes 00/20/24 (8.4.2, 8.4.6, 8.6.6), and privacy rights (Appendix F.5) | Primary, Mastercard's own published rules | Edition dated 4 August 2026, checked 22 October 2026 |
| Mastercard Security Rules and Procedures, Merchant Edition, earlier editions | Dating the change. The 11 February 2025 edition already carries the 11-code table and the 1.5% test. The 22 February 2022, 7 February 2023, 6 February 2024 and 6 August 2024 editions all carry 14 codes, "Reserved for Future Use" at code 06, and the old "1% in any single month" code 04 | Primary, archived via the Wayback Machine | Accessed 2026-08-02 |
| Visa Core Rules and Visa Product and Service Rules | TMF records, common database and regional listing duties (10.10.1.1-10.10.1.2, pp. 646 to 648); separate regional VMSS duties (10.17.1.1, pp. 664 to 665). The cited TMF section gives no numeric excessive-chargeback test | Primary, Visa's public rules | 18 April 2026 edition; Visa citations checked 21 October 2026 |
MATCH and Visa database rules checked 22 October 2026. Earlier archived editions retain their original access dates.
See Also
- Chargeback Ratio Crisis - Crisis response before MATCH
- Network Programs Reference - VAMP, ECM thresholds
- Chargeback Metrics - Calculating your ratio
- Reduce Chargebacks Fast - Immediate triage
- Chargeback Alerts - RDR, Ethoca, CDRN
- Processor Management - Relationship management
- Money Held or Frozen - Understanding reserves
- Buying Payments - Processor selection
- Fraud Prevention - Reducing fraud-based terminations
- PCI DSS Compliance - Avoiding code 12 listings