Wrongfully Placed on the Mastercard MATCH List? What Merchants Can Do

Discovering that your business has been placed on the Mastercard MATCH List can be alarming. A merchant may learn about the listing only after applying for a new payment processing account and being denied, or after an existing processor raises concerns.

For many merchants, the immediate question is simple: Why am I on the MATCH List—and what can I do if the information is wrong?

Not every terminated merchant account should result in a MATCH listing. Mastercard has specific rules governing when merchants may be reported, the reason codes that must support a listing, and the responsibilities of acquiring banks that submit information to MATCH Pro.

If your business was placed on MATCH based on inaccurate information, an incorrect reason code, identity theft, or another reporting error, you may be able to challenge the listing.

What Is the Mastercard MATCH List?

Mastercard MATCH Pro—formerly commonly referred to simply as the MATCH List—is a database used by acquiring banks and other authorized payment-industry participants to identify merchants that have been terminated under specified circumstances.

Being listed can make it substantially more difficult to obtain a new merchant account. When an acquiring bank considers a merchant for payment processing, it can search MATCH Pro and see whether that merchant or its principals match previously reported records.

Importantly, Mastercard's rules do not require listing every merchant whose account is terminated on MATCH. An acquirer must have reason to believe that one of Mastercard's defined MATCH conditions exists when the acquiring relationship is terminated.

Those conditions include excessive chargebacks, excessive fraud, transaction laundering, violations of Mastercard standards, PCI DSS noncompliance, illegal transactions, and identity theft. 

That distinction becomes extremely important when challenging a listing.

What Does It Mean to Be Wrongfully Placed on MATCH?

A merchant may believe a MATCH listing is wrongful when the facts supporting the listing are inaccurate, incomplete, or don't meet the criteria for the reason code used.

That does not necessarily mean that the processor acted illegally or that the merchant automatically has a legal claim for damages. The first issue is usually more fundamental:

Was the merchant properly eligible to be placed on MATCH under Mastercard's rules?

Mastercard expressly requires acquiring banks to take responsibility for the accuracy of their MATCH Pro listings. The rules also state that the acquirer must correct erroneous data entered into MATCH Pro and may face noncompliance consequences if it does not correct inaccurate information within a reasonable period. 

Mastercard further states that an acquirer may not use or threaten to use MATCH Pro merely as a collection tool for minor merchant disputes; one of the applicable MATCH reason-code conditions must be met or suspected to justify adding the merchant. 

Those provisions matter most when a merchant believes a listing resulted from a contractual disagreement rather than conduct that meets a MATCH criterion.

How Incorrect MATCH Listings Can Happen

A disputed MATCH listing can arise in several ways.

A processor may have relied on incorrect chargeback or fraud information. A merchant may have been associated with transactions it did not process. Business ownership information may be inaccurate. The reporting institution's reason code may not match what actually occurred.

Identity theft presents another possibility. Mastercard specifically maintains Reason Code 14 — Identity Theft for situations in which an acquirer has reason to believe that the identity of a merchant or principal owner was unlawfully assumed to enter into a merchant agreement. Mastercard's current rules recognize that the legitimate person or business may not even know its identity was previously used to establish a merchant account. 

Regardless of the circumstances, a merchant should not assume that simply explaining the listing is unfair is enough. A successful challenge generally requires identifying what was reported, why it was reported, and what evidence contradicts it.

What to Do If You Believe Your MATCH Listing Is Wrong

1. Find Out Who Listed You and Why

First, identify the institution responsible for the MATCH entry and the associated reason code. Under Mastercard's current rules, the acquirer must provide the merchant with the ICA identifying who added the merchant and the MATCH reason code. Mastercard also requires an acquirer to respond to questions about a merchant's MATCH listing within seven calendar days after receiving the request. 

Knowing the reason code changes the nature of the dispute.

For example, disputing an excessive-chargeback listing requires a very different analysis from disputing a fraud, transaction-laundering, or standards-violation listing.

2. Compare the Reason Code With Mastercard's Actual Criteria

Do not rely solely on the explanation provided by a sales representative or customer-service employee. Mastercard defines the circumstances associated with each MATCH reason code.

For example, Mastercard's current criteria for Reason Code 04 — Excessive Chargebacks include specific chargeback and dollar-volume thresholds. A merchant challenging that reason code should therefore examine its processing data against the actual Mastercard definition rather than accepting a general statement that the business simply had "too many chargebacks."

The same principle applies to other reason codes. The question is not merely whether the processor had concerns about the merchant. The issue is whether the circumstances support the MATCH reason code that was used.

3. Build a Documentary Record

A MATCH dispute is much stronger when it is supported by records rather than general assertions. Depending on the listing reason, relevant evidence may include processor statements, chargeback reports, transaction records, fraud reports, merchant agreements, termination notices, emails with the processor, PCI compliance documentation, corporate ownership records, or evidence of identity theft.

The goal is to create a clear timeline showing:

1. what allegedly happened;
2. what the acquirer reported;
3. which MATCH reason code was used;
4. why the underlying facts do not support that classification; and
5. what documentation proves the discrepancy.

This is also one reason merchants should preserve processor communications rather than relying exclusively on telephone conversations.

Request Correction or Removal From the Reporting Acquirer

Once the merchant has evaluated the facts, it can present a written challenge to the institution responsible for the listing. Mastercard currently requires an acquirer to respond to a request for removal from MATCH Pro within 30 calendar days of receiving it. 

That does not mean Mastercard requires the acquirer to approve every removal request. It means the request triggers an obligation to respond.

This is an important distinction.

A persuasive removal request should therefore do more than state that MATCH is damaging the business. It should explain precisely why the listing is inaccurate or improper under the applicable MATCH rules and provide evidence supporting that position.

Who Can Actually Remove an Incorrect MATCH Listing?

This is one of the most misunderstood parts of the process.

Mastercard's current rules state that Mastercard may remove a merchant listing when the authorized user reports that it added the merchant to MATCH Pro in error. 

That makes the institution responsible for the original listing particularly important in an error-based removal case.

Simply contacting Mastercard and saying that the listing is unfair may not resolve the underlying issue. The dispute often requires convincing the acquiring bank or responsible authorized user that the merchant should not have been reported under the stated reason code and that the listing should be corrected.

There is a separate removal procedure for certain Reason Code 12 — PCI DSS Noncompliance cases after the merchant has achieved the required compliance. Mastercard's rules even provide a mechanism for the merchant itself to submit a request in that specific situation if the acquirer is unwilling or unable to do so. 

That specific procedure should not be confused with a general right for every MATCH-listed merchant to demand direct removal by Mastercard.

What Happens If the Acquirer Refuses to Correct the Listing?

A processor's refusal is not necessarily the end of the analysis.

At that stage, it becomes important to determine why the acquirer is maintaining the listing, whether the reason code is supported by the available evidence, whether Mastercard's reporting requirements were followed, and whether additional legal or contractual remedies are warranted.

An attorney familiar with payment processing can communicate with the relevant parties, evaluate the merchant agreement and MATCH criteria, organize supporting evidence, and determine the appropriate strategy for challenging the listing.

In some cases, a well-supported dispute may be resolved without litigation. In others, the facts may warrant considering additional legal options.

The strategy depends heavily on why the merchant was listed and what evidence supports—or contradicts—the processor's position.

Don't Simply Wait for the MATCH Listing to Disappear

Mastercard states that MATCH Pro merchant records generally remain in the system for five years, after which they are automatically purged. Five years can be a long time for a business that depends on credit and debit card payments.

Although Mastercard's rules make clear that an acquirer is technically permitted to onboard a MATCH-listed merchant, in practice the listing can substantially complicate underwriting and limit a merchant's processing options. 

That is why merchants who believe a listing is inaccurate should investigate it promptly rather than repeatedly submitting merchant-account applications without understanding what is appearing in MATCH.

Changing Your Business Name Usually Does Not Solve the Problem

Operating under a new company name is not a substitute for addressing an inaccurate MATCH listing.

MATCH Pro can contain information associated not only with the merchant but also with principal owners. Mastercard's system identifies potential matches using multiple data fields, so simply establishing another entity does not necessarily eliminate the underlying issue. 

More importantly, attempting to work around the listing can create additional questions during underwriting.

If the listing itself is wrong, addressing the underlying record is generally more useful than attempting to disguise the connection between businesses.

The Earlier You Understand the Listing, the More Options You Have

A MATCH listing can affect far more than one terminated merchant account. It can interfere with a business's ability to establish new processing relationships, disrupt revenue, and create ongoing problems each time a processor performs underwriting.

But merchants should not assume that every MATCH entry is automatically correct. Mastercard's own rules require accurate reporting, require acquirers to respond to merchant questions and removal requests, and expressly contemplate removal when a merchant was added to MATCH Pro in error. 

If you believe your business was incorrectly placed on the Mastercard MATCH List, first determine who listed you, which reason code they used, and whether the facts support that listing.

TFM Law Can Help Evaluate a Disputed MATCH Listing

TFM Law represents merchants dealing with MATCH List issues, payment processor disputes, and other payment-processing matters. The firm can review the circumstances surrounding a listing, evaluate the applicable MATCH reason code, and communicate with acquiring banks and processors regarding disputed entries. 

If you believe your business was improperly placed on MATCH, contact TFM Law to discuss the circumstances of your listing and the options that may be available.

Request a consultation with TFM Law

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