©2022 Mastercard Proprietary and Confidential Page 4
20. Is a merchant exempt from having to send electronic notices to those cardholders that it has
enrolled prior to the email/electronic notification requirement?
Yes, but Mastercard expects the merchant to make a good faith effort to collect this information
going forward.
21. If a merchant has a mobile app and pushes a billing notification to the app, would this be considered
an electronic receipt?
No, this would not be considered an electronic receipt.
22. Does a text message qualify as an electronic receipt?
Yes, a text message qualifies as an electronic receipt.
23. Can a text message include a link to a page with the terms and conditions and information on how
to cancel?
Yes, but there needs to be a call-out in the communication that the link is where to go for account
management capabilities. For example, “For more information on your subscription, including how to
cancel, click here.” Please note that “Cancel” language is recommended, but not required, in the
communication.
24. For legacy subscriptions, where there is no email address, physical address, or phone number on file
to send a confirmation to the cardholder, how does Mastercard want the merchant to handle these
subscriptions?
The merchant must follow the requirements for all cardholders for which the merchant has contact
information and should be collecting contact information for new cardholders going forward. If a
merchant has no means for contacting legacy cardholders, Mastercard highly recommends (but does
not require) that the merchant include a phone number or web address (URL) in either the “Name”
or “City” field of the transaction message, so that the cardholder has a way to contact the merchant
to manage the subscription as needed.
25. Does a merchant need to track that an electronic confirmation was sent to a cardholder?
Mastercard recommends that the merchant have a process to track, or otherwise validate, that
emails are being sent to cardholders.
26. If an email is returned as undeliverable (e.g., the cardholder provided an incorrect email address),
would the merchant be considered to have performed its due diligence?
Yes, if a good faith effort were made by the merchant to reach the cardholder, then that would be
sufficient to fulfill the requirement.
27. Can transaction receipts for free trial/subscription merchants be sent via monthly marketing
emails?
The email can include marketing information, but it must be clear that it is a receipt, and the
required information should be prominent.
28. If a merchant bills in a six-month billing cycle, would the requirement to send a notification three to
seven days before the billing date apply?
Yes, this requirement would apply to any subscription where the billing frequency is every 6 months
(180 days) or less (e.g., annual billings, semi-annual billings, etc.).