How to Get Removed from the MATCH List: A Step-by-Step Guide

Being placed on the Mastercard MATCH list, formerly known as the Terminated Merchant File (TMF), can feel like a death sentence for a business. It effectively blacklists your company and its principals from the card payment ecosystem, making it almost impossible to secure a new merchant account. While a MATCH listing is a serious obstacle, it is not always a permanent one. This guide explains the process for appealing and seeking removal from the MATCH list, and outlines the steps merchants can take to avoid a listing in the first place.

What is the Mastercard MATCH List?

MATCH, which stands for Member Alert to Control High-Risk Merchants, is a global database operated by Mastercard. When an acquirer terminates a merchant relationship for specific risk-related reasons, they are required by card scheme rules to add the merchant's details to this list. This includes the business name, principal owners' names, and the reason for the termination. Other acquirers are then required to check the MATCH list before boarding any new merchant. If a prospective merchant is found on the list, their application will almost certainly be denied.

Visa maintains a similar system called the Visa Merchant Alert Service (VMAS), previously known as the Terminated Merchant File (TMF), though the industry often uses "MATCH list" or "TMF" interchangeably to refer to the general concept of a merchant blacklist. Being on one list often means you are on the other. The purpose of these lists is to protect the card schemes and their member banks from merchants who pose a significant financial, legal, or reputational risk.

Why Acquirers Add Merchants to the MATCH List

An acquirer cannot add a merchant to the MATCH list without a valid reason code. These codes specify the exact nature of the violation that led to the account termination. While there are over a dozen codes, most listings fall into a few common categories.

Excessive Chargebacks

This is by far the most common reason for a MATCH listing. Card schemes like Visa and Mastercard have strict thresholds for chargeback-to-transaction ratios. For example, under the Visa Dispute Monitoring Program (VDMP) and Mastercard Chargeback Monitored Merchant (CMM) programme, exceeding 100 chargebacks and a 0.9% ratio in a single month will place a merchant into a monitoring programme. Failure to reduce chargebacks and exit the programme will lead to termination and a MATCH listing under Reason Code 04: Excessive Chargebacks.

Fraud and Security Failures

Engaging in fraudulent activity is a direct path to a MATCH listing. This can range from colluding with cardholders to process fake transactions to knowingly selling counterfeit goods. Acquirers use several reason codes to classify this activity:

• Reason Code 03: Excessive Fraud. This is used when an acquirer's fraud monitoring systems detect an unacceptably high level of fraudulent transactions, often measured by the ratio of fraud volume to sales volume.
• Reason Code 05: Excessive Counterfeiting. For merchants found to be selling counterfeit merchandise.
• Reason Code 11: PCI-DSS Non-Compliance. Failure to maintain compliance with the Payment Card Industry Data Security Standard (PCI-DSS) can lead to a listing if it results in a data breach or is deemed a serious security risk.
• Reason Code 12: Transaction Laundering. Processing transactions for another business through your own merchant account is strictly forbidden and results in an immediate listing.

Other Violations

Other reasons for a MATCH listing include bankruptcy, violation of the acquirer's terms of service, or being identified by law enforcement as engaging in illegal activity (Reason Code 10). It is important to note that a simple business disagreement or a standard account closure by the acquirer for commercial reasons is not a valid basis for a MATCH listing.

The Step-by-Step Process for MATCH List Removal

Getting removed from the MATCH list is a formal process that requires patience, documentation, and direct engagement with the acquirer who listed you. You cannot appeal to Mastercard directly. The process must be initiated by the listing acquirer.

Step 1: Identify the Listing Acquirer and Reason Code

Your first step is to confirm you are on the list and understand why. When an acquirer denies your merchant account application because you are on MATCH, they should be able to tell you which acquirer added you and on what date. You must then contact the listing acquirer. They are obligated to provide you with the specific reason code for your listing. This information is critical, as your entire appeal strategy will be built around refuting or mitigating the circumstances of this specific code.

Step 2: Gather Evidence and Build Your Case

Once you know the reason code, you must gather all relevant documentation to prove that the listing was made in error or that the underlying issues have been fully resolved. The evidence required will depend on the reason code.

• For Excessive Chargebacks (Code 04): You need to demonstrate that the chargebacks were illegitimate, that you have implemented new fraud and dispute prevention measures, and that your business model is now stable. This might include transaction logs, customer communications, proof of delivery, and a detailed report on your new chargeback management strategy.
• For Fraud (Codes 03, 05, 12): This is harder to appeal. You must provide compelling evidence that you were not involved in the alleged fraud. For example, if accused of transaction laundering, you need to prove all processed funds were for your own legitimate business activities.
• For PCI Non-Compliance (Code 11): The most direct path is to achieve PCI-DSS compliance and provide a new Report on Compliance (ROC) or Attestation of Compliance (AOC) from a Qualified Security Assessor (QSA).

Step 3: Submit a Formal Appeal to the Listing Acquirer

With your evidence compiled, draft a formal, professional letter to the risk or compliance department of the listing acquirer. Do not send an angry email. Your submission should be structured like a legal document.

1. Clearly state your business name and the names of the principals who were listed.
2. Reference the date of the listing and the reason code provided.
3. Systematically present your counter-evidence for each point.
4. Explain the corrective actions you have taken to prevent a recurrence of the issue.
5. Formally request that the acquirer removes your entry from the MATCH database.

It is often wise to engage a solicitor or a specialist payments consultant who has experience with MATCH appeals. They can help you structure the argument and ensure your submission is taken seriously.

Step 4: Follow Up and Escalate if Necessary

After submitting your appeal, the acquirer will review your case. This can take weeks or months. If your appeal is successful, the acquirer will submit a request to Mastercard to delete the entry. Mastercard will then process the removal. If the acquirer denies your appeal or fails to respond, your options become more limited. You may need to pursue legal action to compel them to remove what you believe is an erroneous listing.