Requirements as of 1 June 2022
Scope of application
These marketing guidelines only apply when you’re marketing Stripe’s Issuing product and services. If you’re only using Stripe Issuing for your own business expenses (and not to facilitate or provide services to your customers) then we wouldn’t expect you to carry out any marketing of Stripe’s products and services (so these marketing guidelines wouldn’t apply).
To offer and promote Stripe’s Issuing products in the United Kingdom and countries within Europe, your user interfaces and advertising must adhere to the guidelines outlined in this document. We’re providing these guidelines to help you navigate the financial regulations that govern the messaging you can use to describe our Issuing product. Deviation from these guidelines can result in poor user experiences and potential regulatory consequences for both you and Stripe. As such, consult both your in-house Legal team and Stripe’s compliance team (email@example.com), if it’s unclear how to apply these guidelines to your user interfaces or advertising.
We’ve organized the relevant information for you in the following components:
- Messaging guidelines
- Pre-approved messages
- Prohibited types of marketing
- User agreements
- Required legal disclosures
- Record keeping and monitoring
In the context of marketing, financial regulations require user interfaces and advertising to be fair, clear, and not misleading (taking into account how the advertising is communicated and whom it is directed to).
All statements must be factual and no important facts can be omitted.
- A misleading statement or omission is “important” if it’s likely to affect the choice of a product or the attitude towards it.
- Price and cost are considered important and should therefore be revealed in the main message.
- Advertising must not emphasize any potential benefits of the product without also giving a fair and prominent indication of any relevant risks:
- Statements must be factual and verifiable
- Disclaimers may not contradict factual statements, they may only explain or modify them.
- Advertising shouldn’t describe a feature of a product or service as “guaranteed,” “protected,” or “secure,” or use a similar term unless (1) those phrases constitute a fair, clear, and not misleading description of the feature of product and (2) the advertising communicates all of the necessary information, and presents that information with sufficient clarity and prominence, and uses the terms fair, clear, and not misleading.
- Advertising relating to a currency transfer service is likely to be misleading if it presents an exchange rate in a way that’s likely to give the impression that the rate is available to a person or a class of persons but in reality that rate is unlikely to be obtained by that person or class of persons with respect to a typical transaction.
All materials must clearly, prominently, and correctly state important terms, including:
- Costs, benefits, and other fundamental points of the products or services offered
- Related products or services offered as an option or requirement to obtain certain terms
- Important limitations or conditions on the terms or availability of products and services, such as time limitations for favorable rates, promotional features, expiration dates, prerequisites for obtaining specific products or services, or conditions for canceling services
- Certain “trigger” words that might require additional legal statements (for example, “free,” “until,” “pre-approved,” “fixed”)
- If advertising compares a product or service with that offered by another provider, the provider must make sure that the comparison is meaningful and presented in a fair and balanced way.
You must draw the user’s attention to fundamental terms, such as limitations and conditions, which are important for the user to make an informed decision.
- Consider the four location principles for providing information: prominence, presentation of information (text size, formatting, on-screen readability), placement of qualifying information, and proximity of all information relevant to the evaluated messages.
- Consider the “big impression” and whether you’re conveying important information or possibly ignoring it.
Avoid images that imply affiliation with, or endorsement of, celebrities, or government entities.
Evaluating marketing materials from a “common user” point of view.
- To determine whether an act or practice is misleading, consider whether your user’s interpretation or reaction to a statement, omission, act, or practice is reasonable in the given circumstances. In other words, whether an act or practice can be unfair or deceptive depends on how a member of the expected audience (its customers) would interpret the statement.
Proof of the claim
- Advertised claims must be substantiated, whether explicit or implicit. “Evidence” means that there must be a reasonable basis for each claim.
- You must disclose limitations necessary to make sure that the claim isn’t false, fraudulent, or misleading.
- You must distinguish “exaggerations,” which don’t need to be substantiated, from allegations. Exaggerations are subjective and generally can’t be proved whether they’re true or false.
- Be careful with using “absolute” terms in the claim like “all,” “only,” or “always” without qualification, these words suggest that there can be no exceptions to the claim.
You must refrain from terms that could imply that this product can be used for consumer purposes.
- Don’t refer to contractor earnings as “wages.”
- Don’t use terms like “Personal Account” or “Consumer Account” to describe the product.
- Don’t use marketing phrases that promote consumer use cases (for example, “Spend funds to buy the things you love!”).
- Don’t describe the card as a “credit card.” This is a commercial prepaid program.
- Don’t market “transferring money” or “sending money” without approved language from Stripe.
- Don’t use words like “bank account,” “deposit account,” “checking account” or similar terms that connote a traditional bank account product.
- Don’t market through advertising mediums which are exclusively dedicated to consumers.
Disparaging remarks about other financial products
- Don’t disparage debit, credit, bank accounts, banks, or other financial products used or issued by financial institutions.
Use of “Registered” or ® markings
- Generally, the brand requirements are that the brand name use the required registration marks. However, after you mention the brand name once, you can stop using it—this is for the same document or material only (for example, your card carrier). We recommend that you use “superscript” in all ® representations.
Marketing of other products and services
- If you advertise products or services other than those provided by Stripe, you must make it clear that those products or services aren’t provided by Stripe.
- If those products or services are regulated financial products, you must not advertise them unless you have the requisite regulatory authorization.
- Although you can ship cards to international addresses for locally domiciled cardholders, you must not engage in marketing the Issuing Program to persons located outside of your relevant jurisdiction (either the UK or Europe as appropriate). This includes advertising or promoting Issuing through marketing channels such as social media, email, and paid search results. As with all other aspects of the Issuing program, you must comply with Card Network rules in connection with marketing activities.
Your marketing team should be familiar with these guidelines as they design advertising campaigns and web pages that market your Stripe Issuing program. Here are some additional considerations for your content:
If mentioning specific product details like, terms, costs, fees, dollar benefits, or any ‘numbers’, make sure they’re accurate:
- Ask: Is it true? How do you know it’s true? Can you prove it with stored data or a reputable source, if asked?
- Ask: Can most users achieve any promised results, and can you prove it, if asked?
- Ask: Do those figures require additional information so users know how they’re achievable? If so, have you disclosed that additional information?
- Ask: Are the product details explained fully?
Here are claims that end up requiring a lot of documentation, and are therefore often avoided:
- Hard to prove claims like: “free”—if you’d like to use this claim contact firstname.lastname@example.org
- Absolute claims: “best,” “#1 or number 1,” “every,” “only,” “all,” “always,” “will get”, or “you’ll get”
- Credit-related statements: “pre-approved,” “fixed,” “earn interest”
- Don’t leave out key details users should know before signing up
- Fake testimonials or quotes about the services
When marketing services and products offered by Stripe, you must use either (a) English or (b) one of the official or commonly used languages of the country where your customer resides.
Prohibited types of marketing
Unless approved by Stripe in writing, you must not market Stripe’s products and services through any of the following types of marketing channels:
You must present user agreements to your prospective customers before they submit their application. This allows businesses to fully understand the terms and conditions of the product before entering into a contract to use Stripe Issuing services. There are a few user agreements that prospective customers need access to depending on their geographic location, including:
Your platform’s terms and conditions must clearly outline any fees or credits that you plan to offer your customers and any activities or qualifications that they need to meet for the fee or credit to be applied.
Additionally, your customers’ cardholders should be prompted to accept the Authorized User Terms before activating their cards.
Because marketing regulations can be cumbersome, we provide pre-approved messaging for communicating the key points of the Stripe Issuing program in your user-facing materials.
We allow non-substantive changes to these messages as long as the key information remains the same. Any substantive changes require approval from Stripe’s compliance team. Approvals can take up to 10 business days to process.
|Limitations on card program use||Cardholders can only use the Card Program for commercial purposes (which means the payment of business expenses), and not for personal, family, or household purposes.|
|Currency||All Card Program cards are GBP or EUR denominated.|
|Where cards can be accepted for payment||Card Program cards can be used anywhere that accepts Visa cards.|
|Where cards can be issued||Card Program cards can only be issued to cardholders who are UK or European incorporated companies or sole traders residing in the United Kingdom or Europe and who have a verifiable physical UK European street address (no P.O. Boxes).|
|Speed of virtual card issuance||Instantly access your own virtual card|
|Speed of physical card issuance||Receive your physical card in a matter of days|
Required Legal Disclosures
For legal reasons, we require that all marketing, including user interfaces and advertisements, include this disclosure:
For UK users:
Cards are issued by Stripe Payments UK Limited, which is an electronic money institution authorized by the Financial Conduct Authority (firm reference number: 900461) for the issuing of electronic money. Cards are issued under the Visa card scheme pursuant to a license from Visa Europe Limited.
For European users:
Cards are issued by Stripe Technology Europe Limited, an electronic money institution authorized by the Central Bank of Ireland (firm reference number: C187865). Cards are issued under the Visa card scheme pursuant to a license from Visa Europe Limited.
Including this disclosure is an essential element of managing your Stripe Issuing program. It gives your users the information they need to validate the legitimacy of the program and escalate complaints to our regulators, if needed.
The disclosure may be placed on your marketing in an area of your choosing, as long as the location follows the location principles described in the “Messaging Guidelines” above. Typically our customers opt to place the disclosures towards the end of their webpage, social media, or email marketing.
Space constrained advertisements
If you’re planning to market through a medium with character limitations which prohibits the full disclosure as set out above (such as in a social media advertisement), include a shortened version of the required legal disclosure, and a link within the advertisement that redirects a user to a webpage with the full legal disclosure.
“Cards issued by Stripe”
Record keeping and monitoring
To demonstrate your adherence to the requirements listed above, we ask that you keep thorough records of all marketing materials, customer data, account information, and other disclosures you make to customers for at least 5 years.
Stripe might occasionally ask you for copies of your marketing materials to make sure they adhere to these guidelines. You must provide copies of these materials within 10 business days of receiving a review request and agree to make any changes that Stripe requests as a result of the review.