Mastercard recently modified its recurring subscription requirements and standards to become best-practice recommendations for most nonprofits or charity merchants that process recurring payments or have sustaining gifts. These standards become requirements ONLY for nonprofit and charity merchants that are identified for at least four months in the Acquirer Chargeback Monitoring Program (ACMP) or similar program. ACMP is a Mastercard program that identifies and mitigates high chargeback rates among merchants. Merchants (including nonprofits) enrolled in ACMP or a similar Mastercard program are still required to follow the new rules.
For more information, see the Blackbaud Mastercard compliance page and the Luminate Online Knowledgebase.
As always, it is best to work with your organization's legal advisor, who is familiar with your practices and constituents, to determine your obligations under the card rules and other requirements to which your organization may be subject. Nothing in this help topic should be construed as legal advice or a legal opinion on any specific facts or circumstances.
Why did Mastercard update the rules?
Mastercard’s subscription rules are changing to provide clarity and transparency to consumers and to discourage the use of billing practices perceived to be harmful or deceptive. Mastercard has confirmed that in some cases recurring gifts, pledges, and donations are classified as subscriptions and fall within the scope of the new rules.
How do I get ready?
If applicable to your organization, the Mastercard deadline for compliance is March 21, 2023. We created this resource to provide examples and instructions for how each requirement can be met using Luminate Online functionality. To read recommendations, expand each requirement below.
Contact Blackbaud Support if you have questions or need assistance.
What do I need to do?
All of the Mastercard Revised Standards regarding recurring subscriptions are now only best-practice recommendations for any nonprofit or charity merchant that utilizes a recurring payment plan. However, all standards become requirements when a nonprofit or charity merchant that utilizes a recurring payment plan is identified for four months or more in the Acquirer Chargeback Monitoring Program (ACMP) as an Excessive Chargeback Merchant (ECM), a High Excessive Chargeback Merchant (HECM) and/or an Excessive Fraud Merchant (EFM) within the same audit period.
If applicable to your organization, review each requirement and recommendation, and complete any necessary actions. Luminate Online contains enhancements to simplify compliance, but some requirements need your attention.
Requirement 1: Point-of-payment disclosure
Mastercard requirement: Subscription terms (price, frequency of billing, and trial period details) must be disclosed at payment. Ecommerce merchants must disclose this on the checkout page (you cannot redirect the customer to another page or site).
Luminate Online recommendation
Online Giving donation form
Action needed: For any donation form that accepts recurring gifts, add the Recurring Gift Terms Acceptance element that is available following the Luminate Online 22.5.2 release. The element adds the following message:
“By completing this step, you authorize the storing of this card account for a payment of [AMOUNT] every [SCHEDULE] for [DURATION].”
See Add a recurring gift terms and acceptance element to a donation form.
Blackbaud Checkout
No action needed. We’ve updated language at the point of payment as follows:
“By completing this step, you authorize the storing of this card account for a payment of [amount] per chosen recurring schedule and future, agreed upon payments.”
Requirement 2: Confirmation by electronic message
Mastercard requirement: An email confirmation or other electronic message must be sent at the time of enrollment outlining subscription terms (price, frequency of billing, and applicable trial period details) as well as instructions on how to cancel.
Luminate Online recommendation
Action required to either provide Gift Service Center or update autoresponder language.
Ensure autoresponders include subscription management language:
(Highly recommended) Set up a Gift Service Center for each active form so donors can modify gift information and payments directly from their constituent account. When enabled, autoresponder emails automatically include a Gift Service Center link where donors can manage their subscription. Enable all Gift Service Center options, especially how to discontinue scheduled payments.
(Required if you do not enable the Gift Service Center; otherwise optional) Update Sustaining and Installment Autoresponder language to include an email address or phone number that a donor can use to manage or cancel the subscription.
“You can stop your monthly giving at any time. Call us at 555-555-5555 (Monday‒Friday, 8 a.m.‒5 p.m.) or send us an email at example@nonprofit.org to change or cancel your monthly pledge.”
Requirement 3: Electronic receipts for each payment
Mastercard requirement: For customers who have an email on file with your organization, an email receipt or other electronic message must be sent after each recurring gift, pledge, or membership and include cancellation instructions.
In early September 2022, Mastercard clarified that monthly notification (receipting) is ONLY required for donors who have provided an electronic method of communication (for example, email address, cell phone). Nonprofits will not need to generate receipts by alternate means (such as postal mail) for recurring donors whose electronic methods of communication are not available.
Luminate Online recommendation
Online Giving donation form
Update the language of your One-Time and Sustaining Gift Receipts to include the link to your Gift Service Center or other cancellation means (for example, add an email address or phone number).
Blackbaud Checkout
If you haven't already, configure and associate a receipt with any campaign that uses Blackbaud Checkout. See Generate Sustaining Receipts.
Requirement 4: Electronic cancellation method
Mastercard requirement: An electronic cancellation method must be provided (similar to unsubscribing from email messages or any other electronic method).
Luminate Online recommendations
Donors do not need to be able to cancel online. However, on your website or in emails, you must provide clear instructions on how donors can cancel their recurring payments.
We recommend three updates:
(Highly recommended) Set up a Gift Service Center for each active form so donors can modify gift information and payments directly from their constituent account. When enabled, autoresponder emails automatically include a Gift Service Center link where donors can manage their subscription. Enable all Gift Service Center options, especially how to discontinue scheduled payments.
(Required) Update your organization's website with guidance on managing recurring payments.
“You can stop your monthly giving at any time. Call us at 555-555-5555 (Monday‒Friday, 8 a.m.‒5 p.m.) or send us an email at example@nonprofit.org to change or cancel your monthly pledge.”
(Required if you do not enable the Gift Service Center; otherwise optional) Update Sustaining and Installment Autoresponder language to include an email address or phone number that a donor can use to manage or cancel the subscription.
You can:
Update an individual donation form's autoresponder language .
--OR--
Update the default version in the Autoresponder Center to apply to all donation forms.
To update language of the default autoresponder to apply to all forms:
Go to Setup > Autoresponder Center.
Select the Application Autoresponders tab.
Locate the autoresponders for Donation Forms.
Locate the Sustaining and Installment autoresponders.
Select Edit, then follow the instructions in this help topic to copy the autoresponder, make updates, Save, and Activate your new autoresponder.
Requirement 5: Prenotifications for plans that only bill every 6+ months
Mastercard requirement: For subscription or recurring payment plans that bill a cardholder less frequently than every six months (180 days), you must send a notification no less than three days and no more than seven days before the billing date. The notification must include the terms of subscription and how to cancel the subscription.
Luminate Online recommendation
Note: Infrequent donor autoresponders are disabled by default so that you can review and update autoresponder language before sending the emails to your infrequent donor supporters. To send the autoresponders, enable the task described below.
Action required. First, update the language in autoresponders that are sent to notify infrequent recurring donors of an upcoming billing. Then, enable a daily task to identify those donors and send out the autoresponders.
To review and update the autoresponder language for infrequent donors, you can update an individual email's autoresponder language or update the default version in the Autoresponder Center to apply everywhere it is used. The Next Sustaining Payment Notification and Next Installment Payment Notification autoresponders notify infrequent recurring donors of an upcoming billing.
The daily Recurring Donor Notification Task identifies recurring donors whose payments are spaced six months or more apart and will be charged in five days. Once identified, autoresponder emails are sent to the donors to remind them about their upcoming billing, subscription terms, and how to cancel the subscription.
Enable the daily Recurring Donor Notification Task to identify and send the autoresponders by going to Setup > Site Options, and setting DON_RECURRING_PLEDGE_NOTIF_TASK_EXECUTION_ENABLED to TRUE.