The MATCH List and iGaming: How to Stay Off It — and What to Do If You're On It

The MATCH list (Member Alert to Control High-Risk Merchants) is the payment industry's blacklist. Being placed on MATCH means no Visa or Mastercard acquirer will board you as a new merchant — anywhere in the world — for five years. For iGaming operators, MATCH placement is more common than in most industries, and the consequences are existential: you cannot process card payments, which for most operators means the business cannot operate.

This guide explains exactly what MATCH is, the 13 placement reason codes, how to check whether you are listed, and the legitimate pathways available if you are. It is written specifically for iGaming operators, compliance officers, and payment managers who need precise, actionable information — not generalities.

Table of Contents

1. What Is the MATCH List?
2. The 13 MATCH Placement Reasons (With iGaming Context)
3. Who Gets Reported: Merchant Entity and UBOs
4. How to Check Whether You Are on the MATCH List
5. How Long MATCH Listing Lasts — and the Removal Process
6. What Payment Options Are Available for MATCH-Listed Operators
7. How to Avoid MATCH: The Practical Prevention Checklist
8. FAQ

What Is the MATCH List?

MATCH stands for Member Alert to Control High-Risk Merchants. It is administered by Mastercard and was previously known as the Terminated Merchant File (TMF) — a name still widely used in the industry. When an acquirer terminates a merchant relationship for cause, the acquirer is required in most cases to report that merchant to MATCH within three business days.

All Visa and Mastercard acquiring banks globally access MATCH before onboarding any new merchant. It is a mandatory step in merchant underwriting, not an optional check. There is no approved acquirer in the Visa or Mastercard network that can knowingly board a MATCH-listed merchant for card processing.

The database entry for a reported merchant contains:

• Legal entity name and DBA (trading) name
• Principal and UBO names (typically all individuals with ≥25% ownership)
• Physical address and country of incorporation
• Tax identification or registration number
• The reason code for the termination

MATCH is not a public database. Merchants cannot query it directly. Only licensed Visa and Mastercard acquirers — banks and payment processors that hold acquiring licences — can access the database. If you suspect you may be listed, you must ask an acquirer or a specialist intermediary with acquirer access to check on your behalf.

The global scope is often underestimated. MATCH is not a regional or UK-only system. A filing made by an acquirer in Malta, Cyprus, Curaçao, or Gibraltar is visible to every acquiring bank in the world, including those in Asia, Latin America, and Africa. There is no jurisdiction-by-jurisdiction workaround.

The 13 MATCH Placement Reasons (With iGaming Context)

Mastercard assigns a reason code to every MATCH filing. Understanding these codes is essential: the reason code determines how egregious the filing appears to future acquirers who review your history, and it affects what — if any — remediation is possible.

Which Codes Hit iGaming Operators Most Often

Reason 04 (Excessive Chargebacks) is by far the most frequent cause of MATCH placement for iGaming operators. The 1% threshold sounds forgiving, but iGaming chargeback rates can spike rapidly during player disputes, bonus abuse incidents, or payment descriptor confusion (players filing chargebacks because they do not recognise the descriptor on their card statement).

Reason 10 (Illegal Transactions) is the second most common. This includes processing for players in jurisdictions where online gambling is prohibited, operating without the required licence for a particular market, and UIGEA-related violations for US-facing operators. Geolocation controls that fail to block VPN users are a frequent trigger.

Reason 03 (Laundering) is specifically used where operators are processing gambling transactions through entities with non-gambling MCCs — typically holding companies or affiliate entities — to obscure the nature of the underlying transactions. This is a serious filing that raises AML red flags beyond MATCH itself.

Reasons 01, 02, and 05 are significant but less frequent, typically arising where an operator's payment infrastructure has been compromised or where fraud rates at a particular processor are traced back to that operator's transaction flow.

Who Gets Reported: Merchant Entity and UBOs

This is the most misunderstood aspect of MATCH, and the one that causes the most damage.

MATCH does not list only the terminated merchant entity. It lists the principals — defined as individuals who own, control, or have significant influence over the merchant. In practice, this means all UBOs with 25% or greater ownership are individually listed alongside the entity.

The implications are significant:

• If Merchant Co Ltd is MATCH-listed, and John Smith owns 50% of that company, John Smith is personally listed in MATCH.
• If John Smith subsequently forms New Merchant Ltd and applies for merchant acquiring, the new entity will fail MATCH screening because John Smith — a listed principal — appears as a UBO.
• The personal listing follows John Smith across all business activities for five years from the date of the original filing, regardless of the industry or the nature of the new business.

This is why UBO identity verification is a standard and non-negotiable step in merchant underwriting. It is not merely KYC formality — it is specifically designed to prevent MATCH-listed individuals from circumventing the blacklist through new corporate structures.

The practical consequence for iGaming operators is that a MATCH listing at an operating subsidiary level can effectively shut down the entire group's ability to process card payments, if the UBOs are common across entities.

Joint ventures and minority stakes are not exempt. If an individual holds a 30% stake in a MATCH-listed entity, that individual is listed. They cannot argue that their minority position insulates them.

How to Check Whether You Are on the MATCH List

You cannot search MATCH directly. There is no consumer-facing portal, no self-service check, and no official process for a merchant to query their own status. The options available are:

1. Ask a Prospective Acquirer

Any bank or PSP going through merchant underwriting will check MATCH as a standard step. If you are declined and the stated reason is vague — "negative background check", "risk appetite", "unable to proceed at this time" — ask specifically whether a MATCH listing was identified. Acquirers are not always forthcoming with this information, but they should confirm it when asked directly.

The risk with this approach is that declined applications accumulate. Multiple declined applications across different acquirers, all triggered by the same MATCH listing, create a pattern that some acquirers flag independently of the MATCH record itself.

2. Use a Specialist Intermediary

High-risk payments brokers and banking advisers with established acquirer relationships can perform MATCH pre-checks before you formally approach any acquirer. GetBanked can perform this check as part of a pre-approval process, so you understand your exact position before any formal application is submitted.

This is the recommended approach. It avoids the declined-application trail and gives you accurate information to plan against.

3. Ask Your Previous Acquirer

The acquirer who terminated your account is required to notify you if they submitted a MATCH filing. They may not volunteer this information proactively — and in practice, many do not. Ask in writing, specifically: "Did you submit a MATCH filing in connection with the termination of our merchant account?" Retain their written response.

If they confirm a filing, ask for:

• The date the filing was submitted
• The reason code applied
• The entity name(s) and principal name(s) included in the filing

This information is essential for any subsequent removal attempt or legal review.

How Long MATCH Listing Lasts — and the Removal Process

Standard Duration

A MATCH listing remains active for five years from the date the original acquirer submitted the report. This is a fixed period set by Mastercard's rules. There is no automatic review, no parole equivalent, and no mechanism for good behaviour to reduce it.

After five years, the record is automatically purged from the active MATCH database. Acquirers running checks after the five-year period will not see the historical listing.

Early Removal

Early removal — before the five-year period expires — is possible only through one mechanism: the original acquirer who filed the report submits a formal removal request to Mastercard.

Grounds for removal are narrow and specific:

1. Clerical error — the wrong entity or individual was listed (name mismatch, incorrect registration number, wrong UBO included)
2. Acquisition reversal — the acquirer reinstated the merchant relationship and the termination that triggered the filing was reversed
3. Documented legal ruling — a court or regulatory body has ruled that the acquirer's termination was wrongful, and the acquirer accepts the ruling

What does not qualify for removal:

• Subsequent clean processing history with alternative payment methods
• Obtaining a new gambling licence or upgrading an existing licence
• Changing the business model or ownership structure of the original entity
• Creating a new legal entity
• Providing evidence of improved chargeback management
• Simply waiting and asking the acquirer to reconsider

In practice, early removal for legitimately placed MATCH filings almost never happens. Acquirers have no commercial incentive to submit removal requests unless legally compelled to do so, and the grounds for compelling them are narrow.

If you believe a filing contains errors — particularly regarding the entity names, UBO names, or the reason code applied — a legal review is warranted. There are solicitors and payments consultants who specialise in MATCH dispute work. The cost is significant; the success rate for legitimate errors is reasonable; the success rate for challenging accurately-filed records is very low.

What Payment Options Are Available for MATCH-Listed Operators

MATCH listing blocks Visa and Mastercard card processing globally. It does not block all payment options. The following alternatives are available to MATCH-listed operators, with an honest assessment of each.

Bank Transfers (Open Banking / Instant Payment Rails)

Bank-to-bank transfer rails — Open Banking in the UK and EU, SEPA Instant, Faster Payments — do not query the MATCH database. An iGaming operator with a valid bank account (see EMI section below) can accept player deposits via bank transfer.

The conversion rate is substantially lower than cards. Players accustomed to card deposits find bank transfer flows less immediate and more friction-heavy. In regulated markets with strong Open Banking adoption (UK, Germany, Netherlands), conversion rates of 40–60% of card-equivalent volume are achievable. In less developed markets, bank transfer coverage is sparse.

Cryptocurrency Payment Gateways

Crypto acceptance — Bitcoin, Ethereum, USDT, and other major assets — involves no Visa or Mastercard network and therefore no MATCH screening. Operators can integrate via processors such as commission-based crypto payment processors, or a commission-based crypto payment processor, or build direct wallet-based deposit flows.

Crypto is increasingly mainstream in iGaming, particularly in crypto-native markets and jurisdictions where crypto gambling is explicitly permitted. Regulatory acceptance of crypto as a payment method varies significantly by licence jurisdiction — UKGC-licensed operators face restrictions; MGA-licensed operators have more flexibility.

Crypto does not solve all problems: settlement into fiat requires banking infrastructure, which brings its own challenges for MATCH-listed operators.

E-Wallets: major European e-wallets

major European e-wallets (both owned by Paysafe) are widely used in iGaming and do not screen MATCH for their merchant onboarding. They maintain their own risk review processes, which assess chargeback history, regulatory standing, and business model — but these are independent of the Mastercard MATCH database.

Operators with MATCH listings related to chargeback issues may face scrutiny from a major European e-wallet/a major European e-wallet's own risk teams, but the MATCH listing itself is not determinative. Many MATCH-listed operators continue to process through major European e-wallets.

a major global payment provider actively excludes most gambling activity and is not a viable option for most iGaming operators regardless of MATCH status.

Alternative Card Schemes

Discover, American Express, JCB, and China UnionPay do not use Mastercard's MATCH database. They maintain their own terminated merchant lists and risk databases, which are separate systems.

However: operators with significant chargeback or fraud history are likely to have that history visible through other mechanisms — industry shared databases, acquiring relationships, and reputational channels. Simply applying to Amex with a history of excessive chargebacks is unlikely to result in approval, even though MATCH itself is not queried.

The practical value of alternative card schemes for MATCH-listed operators is limited. Their aggregate market share is small relative to Visa and Mastercard. China UnionPay has meaningful coverage for Chinese player bases. JCB for Japanese players. Neither is a substitute for Visa/Mastercard processing.

Voucher Solutions

Prepaid voucher schemes — Paysafecard being the market leader — are deposit-only solutions that are entirely card-network-independent. Players purchase vouchers with cash at retail points and redeem them at the operator. No chargebacks are possible because there is no card involved. MATCH is irrelevant.

Paysafecard has its own merchant onboarding process and actively screens for regulatory compliance. A MATCH listing will not disqualify you directly, but operating without a valid gambling licence in an accepted jurisdiction will.

Vouchers address the deposit side only. Withdrawals still require bank transfer or e-wallet infrastructure.

EMI Accounts for Settlement Infrastructure

Electronic Money Institutions (EMIs) — regulated under the Electronic Money Regulations in the UK or equivalent EU frameworks — can provide business accounts capable of receiving and holding player funds, executing bank transfer withdrawals, and settling payments from alternative payment providers.

EMIs are not acquiring banks and do not process card transactions, so MATCH does not apply to their account-opening decision. Their own risk assessments apply, which will consider the operator's regulatory standing, licence jurisdiction, UBO background, and any adverse payment history.

For a MATCH-listed operator, EMI accounts are typically the foundational piece of the payment infrastructure — receiving settlements from Open Banking providers, e-wallets, and crypto processors, and processing player withdrawals.

The Honest Assessment

MATCH-listed operators can still operate, but at significantly reduced payment coverage. Card payments represent 60–80% of deposit volume for most iGaming operators in card-dominant markets (UK, most of Western Europe, Australia). Operating without Visa and Mastercard is viable in some configurations and some markets, but it is not equivalent to having full card access. The revenue impact is material.

Operators who find themselves MATCH-listed typically need a 12-to-24-month alternative payment strategy while the listing runs its course, combined with a plan to resolve the underlying issues that caused the listing, so that the five-year period genuinely ends the restriction.

How to Avoid MATCH: The Practical Prevention Checklist

MATCH placement is avoidable in most cases. The majority of iGaming MATCH filings result from manageable operational failures — specifically, chargeback mismanagement and processing in prohibited markets. The following checklist covers the key prevention measures.

1. Keep chargeback ratio below 0.65% at all times. The formal threshold that triggers Mastercard's Excessive Chargeback Programme is 1.0%. Do not use 1.0% as an operational target — by the time you reach it, you are already inside the window that leads to acquirer termination. Treat 0.65% as the hard ceiling and 0.5% as the operational target. If your ratio approaches 0.65%, implement remediation immediately.
2. Never process transactions from jurisdictions where gambling is illegal. Geolocation verification must block players from prohibited markets at the point of registration and at the point of deposit. VPN detection is a necessity, not a nice-to-have. The jurisdictions most commonly cited in Reason 10 filings are the United States (UIGEA), China, and markets where your specific licence does not confer authorisation to operate.
3. Maintain PCI DSS compliance appropriate to your payment flow. For redirect payment flows where you never handle raw card data, SAQ A is the minimum. If you store, process, or transmit cardholder data in any form, SAQ D or a full QSA assessment applies. A breach at any point in the flow can trigger Reason 01 — and PCI non-compliance at the time of a breach removes any mitigating factors.
4. Disclose all UBO and corporate structure information accurately at merchant onboarding. Misrepresentation in the application is itself a potential MATCH reason (Reason 11 — Identity Theft, or Reason 12 — Noncompliance). More importantly, discovered misrepresentation damages your relationship with the acquirer and eliminates goodwill in any subsequent termination negotiation.
5. Do not route transactions through entities with different MCCs to obscure gambling activity. This is Reason 03 — Laundering. Some operators attempt to process gambling transactions through holding companies or management service entities with MCCs such as 7372 (Software) or 7389 (Services NEC) to avoid the scrutiny applied to MCC 7995. This is detected by card network monitoring and results in the most serious class of MATCH filing.
6. Communicate proactively with your acquirer if you are approaching account closure. A negotiated exit — where you and the acquirer agree to wind down the relationship in an orderly way — is not a MATCH filing. MATCH is triggered by acquirer termination for cause. If your acquirer is concerned about your chargeback ratio, your volume profile, or your licence situation, engage directly. Ignoring warning letters and allowing the relationship to deteriorate to formal termination is the most avoidable path to MATCH.
7. Request written confirmation that no MATCH filing will be made before agreeing to close a merchant account. If you are voluntarily closing an account or agreeing to a mutual termination, get written confirmation from the acquirer that they are closing the account without a MATCH filing. This protects you if the acquirer subsequently files a report you were not expecting.
8. Check your principals for prior MATCH status before applying to any acquirer. If you are bringing on a new director, significant shareholder, or UBO, perform a MATCH pre-check on those individuals before they are formally associated with your merchant account applications. Discovering a MATCH-listed UBO after a formal application has been declined is significantly more damaging than discovering it beforehand.

FAQ

Can I get a new merchant account if I am on the MATCH list?

Not with any Visa or Mastercard acquirer, anywhere in the world. MATCH screening is a mandatory underwriting step, and acquirers cannot knowingly board MATCH-listed merchants. Alternative payment methods — bank transfers, e-wallets, crypto, vouchers — are available and do not query MATCH, but full card processing is blocked for the five-year listing period.

Does MATCH apply outside the UK and EU?

Yes, globally. MATCH is a Mastercard-administered global database, and all Visa and Mastercard acquirers in every country are required to query it before onboarding new merchants. There is no jurisdiction where MATCH is not applicable to acquirers operating within those networks. Acquirers in Malta, Cyprus, Curaçao, Isle of Man, Gibraltar, Singapore, and all other iGaming-friendly jurisdictions screen MATCH.

If I start a new company, will it be affected by the MATCH listing on my old company?

If the new company shares any UBO who is personally listed in MATCH — and personal listings follow individuals with ≥25% ownership — then yes, the new entity will fail MATCH screening because the listed individual is identified as a principal during underwriting. A new corporate structure does not remove the personal listing. This is one of the most common misconceptions about MATCH.

How do I get removed from the MATCH list before five years?

Only the acquirer who originally filed the report can submit a removal request to Mastercard. They will do so only if the filing contained a documented error (wrong entity, wrong individual, incorrect reason code) or if there is a legal basis compelling them to do so. There is no process by which the merchant can directly petition Mastercard for removal. If you believe your filing contains errors, engage a solicitor or specialist payments consultant to review the filing details and advise on whether a challenge is viable.

Is the MATCH list the same as the Terminated Merchant File (TMF)?

Yes. TMF was the previous name for the same database, administered by Mastercard and covering Visa and Mastercard networks globally. The name changed to MATCH — Member Alert to Control High-Risk Merchants — but the system, the rules, and the five-year duration are the same. Both terms are still used in the industry; if an acquirer or payments consultant references your "TMF status", they mean MATCH.

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