Updating your terms and conditions to make sure customers have been given a mandate to collect recurring payments for Strong Customer Authentication (SCA) purposes

We cannot provide exact wording to update your terms and conditions as you know your business best, including the types of payments you need to obtain your customers’ consent to collect.

At a minimum, you should ensure that your terms cover:

Ultimately, what your customer pays for, the frequency of payments and how the amount of the payment(s) will be determined is something we expect you already cover in your terms and conditions (although you should check this and confirm it is the case).

You could use the following text to obtain the customer’s consent to you initiating payment(s) on their behalf:

“I authorize [your business name] to send instructions to the financial institution that issued my card to take payments from my card account in accordance with the terms of my agreement with you.”

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This Q&A is for informational purposes only. It is not legal advice. Please reach out to your legal counsel to receive tailored guidance on how SCA may impact your business.