The information in this page does not constitute legal advice. It only provides an overview of Adyen's compliance guidelines for financial products and Adyen for Platforms (referred to as the Compliance Guidelines). For additional, non-legal clarifications about this content, reach out to your Adyen contact.
Marketing Materials
Collateral material is defined as all communication that the user sees in relation to Adyen's offering through your platform’s interface. We also refer to this communication as collateral material.
Collateral materials can include, but are not limited to:
- Platform web pages,
- Platform user interface pages (for example, application flow, customer dashboard, support pages),
- Platform marketing communications,
- Platform communication to users,
- User statements,
- Direct mail advertisements,
- Other print or media advertisements,
- Press or media releases,
- Advertisements,
- Materials accompanying card distribution(carriers, pin mailers, proprietary packaging)
- Physical or Virtual Card Proofs
- App store descriptions and screenshots of platforms
All collateral material used by the platform must:
- Adhere to the general principles listed below for each product offering; and
- Include relevant bank disclosures (as detailed in Adyen’s Disclosure and Consent Procedure) for each service offered.
For all financial products, all collateral material used by the platform must:
- Be reviewed and pre-approved by Adyen before publishing or distributing;
- Resubmitted for approval to merchantkyc@adyen.com when changes are made, excluding typographical or grammatical error changes. Changes that do not impact the description or marketing of the Adyen product or service content do not need to be resubmitted for approval. Content can be submitted for use in multiple collateral materials.
- Any additional collateral material that the platform wishes to publish following go-live should also be submitted for approval to merchantkyc@adyen.com.
General Principles
Communication style
- All collateral material must be written in plain language.
- Material must be tailored to the target customer, in accordance with their level of sophistication; non-sophisticated customers generally require simpler (jargon-free) communication.
- All collateral material should present terms, benefits, limitations, availability and risks of the Service line adequately, accurately, clearly and conspicuously. Collateral materials must not make claims, representations, or statements that are misleading to the target customer.
- All representations within the collateral materials should be reasonable and factual. If claims are made that require additional data to support them, source or disclose the additional data. Any research, statistics or claims quoted in collateral materials must be substantiated and refer in the advertisement to the source of the research or statistics, or grounds for the claim, including the date of the research or statistics and any assumptions that have been made based on the research, statistics or claims.
- Where used, the collateral material must explain the meaning of any abbreviations or acronyms.
- Where more than one financial service is advertised in collateral material, the collateral material must clearly distinguish which service the provided information relates to.
Testimonials
- If using testimonials or endorsements in collateral materials, the testimonial must be a real customer, using the Service they are talking about. The testimonial or endorsement must be attributed to the author of the statement and correctly dated. Permission must be obtained in writing to use the testimonial or endorsement. If any money was paid to the customer for the testimonial or endorsement, a disclaimer must be included stating this fact.
- Any comparisons or contrasts in the information provided in collateral material must either be based on verified facts or reasonable assumptions stated within the advertisement. The comparisons or contrasts must be specified in a clear, fair and balanced way and not omit any key information.
- The collateral material should include a reference to the Platform’s contact information (i.e., phone number, website address, or email address).
Vocabulary to avoid
- Avoid using exaggerated or unsubstantiated claims or absolute statements that are hard to prove. For example: “all”, “never”, “always”, “fastest”, “cheapest”, “lightning speed”, “prevents all fraud”.
- Avoid the use of the term “free” if there are charges, costs or fees that may be outlined in user terms.
- Avoid using terms such as “pre-approved” or “guaranteed”. If using those terms, it must be clear if there are any limitations, conditions, or restrictions on the offer. However, the term “pre-qualified” may be used.
- Avoid using terms such as “protected” or “secure”. If using those terms, it must be clear if there are any limitations, conditions, or restrictions on the offer.
- Materials must not require a consumer credit check or consumer credit report or infer that a consumer credit check is performed in order to grant the product.
Forbidden content:
- Collateral material must not include language or images that are profane, sexual or political in nature, are offensive, including to racial or religious classes, or language that is defamatory towards other third parties.
Format/Layout:
- The design and format of all collateral material must not obscure or disguise any key information concerning the service. Key information must always be confirmed in writing.
- Any disclosures in the collateral material must be done in the predominant font size, i.e., a font size large enough to read and in a color that visibly contrasts with the background.
- Recommended: 8-point font for paper materials; 10-point font for online materials
- Key information or disclosures should not be buried in other non-key disclosures or footnotes. Footnotes shall only be used to supplement or elaborate on the key information included in the body text.
- Recommended: footnotes should be no more than 2 points smaller than the font size used for the body of the text
- All communications should be accessible to users of differing abilities (for example, all websites should be compatible with text-to-speech technology).
- Collateral materials may only include a hyperlink linking to information that forms part of the advertisement where the advertisement containing the link specifies the name of the advertised financial service and/or an invitation to discuss the financial service in more detail. In addition, the hyperlink must be displayed prominently and link directly to the additional information on a single webpage.
Specific disclosures for countries/regions
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(UK only) Platforms shall include on their webpage or application a clear explanation on the role of Adyen as provider of the regulated financial service versus the role of the platform. Example below:
- “To facilitate payments and offer financial products, [Platform] works together with Adyen UK, which is authorised by the Prudential Regulatory Authority and the Financial Conduct Authority."
- More information on Adyen and its offering can be found in the FCA’s register (firm number 779800) and Adyen's United Kingdom page.
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(Ireland only): Any webpage on the Platform’s website that relates to a financial service offered in partnership with Adyen, that is accessed from someone based in Ireland, must display the following statement:
- “We work with Adyen N.V. to offer financial services. Adyen N.V., trading as Adyen, is authorised by De Nederlandsche Bank in the Netherlands and is regulated by the Central Bank of Ireland for consumer protection rules.”
Product-specific requirements
Collateral material review principles for Issuing
| Representation | EU | AU | UK |
|---|---|---|---|
| Platform’s Card Program Name and network name text the same size | ![]() |
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| Language must not suggest the card is a bank card/bank account card | ![]() |
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| An issuing statement is required to appear anytime the card, payment scheme/network brand marks or logo is portrayed, identified or displayed in any form of collateral. A program can work with Adyen to request a variance from the Schemes. Please refer to each network’s guidelines for approved variances of the below statements. EU
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| For physical and virtual cards, the network standards must be met for required elements, prohibited elements, and card images. | ![]() |
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| The use of cards in any marketing material or advertisements must meet network standards and card image standards. | ![]() |
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| USA PATRIOT Act must be disclosed when an individual’s personal information is collected. | ![]() |
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| PREPAID Card Programs: Use language promoting the benefits of the card such as “better than cash”, “spend only what you load”, “spend only what you have on the card”. Avoid using phrases like “better than credit”, “no interest”, “no debt”, “debit card”, “credit card”. |
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| For General Purpose Reloadable (GPR) Prepaid Cards Programs: The card must not be marketed or labeled as a gift card or gift certificate, meaning either directly or indirectly offering, advertising or otherwise suggesting the potential use of a general-use prepaid card as a gift for another person. Examples of marketed or labeled as a gift card or gift certificate include:
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| For Business-Purpose Card Programs: Indicate that the card can be used for “business needs” or “commercial needs” and can not be used for personal, family, or household purposes. Avoid using phrases like “Use card program for anything you want”, “personal cards”, “use these cards like a payday loan”. Do not use consumer use cases in Collateral materials. |
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| Collateral material must truthfully reflect the program scope and specifications agreed upon in the Card Service Agreement. | ![]() |
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| Any use of the Visa and Mastercard Marks must not degrade, devalue, denigrate, or cause injury or damage to the Marks or the Schemes in any way. | ![]() |
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| Platform must not use “bank” or “banking” in their website name. | ![]() |
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| If the Platform uses “bank” or “banking” in any materials, there must be a disclosure stating that the program is not a bank and the program is provided by Adyen, N.V. | ![]() |
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Collateral material review principles for Business Accounts
| Representation | EU | AU | UK |
|---|---|---|---|
| Platform must not use “bank” or “banking” in their website name or infer that the Platform itself is the provider of the bank account. | ![]() |
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| Platform cannot use the word “bank account” but solely “business account” or “e-money account”. | ![]() |
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| Platform cannot state “open a [Platform] bank account” or similar language. There must be a disclosure stating that the Platform is not a bank and that the account is a business account provided by Adyen, N.V. | ![]() |
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Any FAQ must explain that the accounts are held at:
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| Provide disclosure that: In the EU, Adyen N.V. is registered with the Dutch deposit guarantee scheme register and eligible funds up to EUR 100,000 are legally protected by the Dutch deposit guarantee scheme. |
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| Provide disclosure that: Business Accounts offered by Adyen N.V. London Branch include issuance of electronic money. Electronic money is not a deposit and therefore not protected by the Financial Services Compensation Scheme. |
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| Must distinguish that the account is not FDIC Insured using the approved statement below: Adyen Business Bank Accounts in the U.S. are not insured by the FDIC and are not guaranteed by the Federal Government. If Adyen places deposits in a cash sweep program utilizing FDIC insured depository institutions, such deposits may be covered by FDIC insurance up to applicable limits in accordance with the FDIC rules, including those relevant to the aggregation of multiple accounts. |
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Collateral material Review Principles for Adyen Capital
Loans
| Representation | EU | US | AU | UK | CA |
|---|---|---|---|---|---|
| Disclose that Capital is provided by Adyen N.V. | ![]() |
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| Disclose that Capital is provided by Adyen N.V. UK Branch | ![]() |
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| Disclose that Capital is provided by Adyen Australia Pty Limited Adyen Capital is provided by Adyen Australia Pty Limited ABN 55 162 682 411. Adyen Capital is offered exclusively for business purposes and not for any personal, domestic or household use. Minimum qualifications and eligibility may change from time to time. Adyen reserves the right to withhold Adyen Capital from users who do not meet minimum qualifications. Please see full terms and conditions. |
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| Include the disclosure: Loans are issued by Adyen N.V. San Francisco Branch and subject to credit approval. | ![]() |
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| Include disclosure: Please note that Loans provided by Adyen do not qualify as regulated credit agreements under the Consumer Credit Act. | ![]() |
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| Disclose that Capital is provided by Adyen Canada Ltd. | ![]() |
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| Disclose that the rate charged for Capital is fixed. | ![]() |
Merchant Cash Advances
| Representation | EU | AU | UK |
|---|---|---|---|
| Do not misrepresent a cash advance as a loan. | ![]() |
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| Do not make reference or compare to other loan products or products that have a credit element. | ![]() |
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| Disclose that Capital is provided by Adyen N.V. | ![]() |
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| Disclose that Capital is provided by Adyen N.V. UK Branch | ![]() |
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| Disclose that Capital is provided by Adyen Australia Pty Limited Adyen Capital is provided by Adyen Australia Pty Limited ABN 55 162 682 411. Adyen Capital is offered exclusively for business purposes and not for any personal, domestic or household use. Minimum qualifications and eligibility may change from time to time. Adyen reserves the right to withhold Adyen Capital from users who do not meet minimum qualifications. Please see full terms and conditions. |
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| If a communication names the FCA, PRA or both as the regulator of Adyen, make clear that Merchant Cash Advances are not regulated by the FCA, PRA or both. | ![]() |
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| Include disclosure: Please note that Merchant Cash Advances provided by Adyen do not qualify as regulated credit agreements. | ![]() |
