Suspect you are on the MATCH list: UK action runbook

First action: confirm the listing

You cannot query the MATCH database. The practical UK confirmation route:

1. Apply to a mainstream UK acquirer you have not used before (SumUp, Square or Stripe).
2. If declined, ask in writing: "Please confirm whether the decline was based on a MATCH listing, and if so, the reason code used."
3. Most UK acquirers will confirm if pressed. Stripe and SumUp are reliably forthcoming; Square sometimes refuses.
4. Multiple mainstream declines (3+) without other obvious reasons is a strong indicator.
5. Definitive: ask the acquirer that terminated you for written confirmation of whether they listed you and under which code.

What MATCH is, in one paragraph

MATCH (Member Alert to Control High-Risk Merchants) is Mastercard's global database of merchants whose accounts have been terminated under one of 13 reason codes. UK acquirers must check MATCH on every new merchant application. Listings stay for 5 years and cover the merchant entity plus principal owners (directors, beneficial owners 25%+). The Visa equivalent (VMSS) operates similarly but is less widely populated. For more detail, see our MATCH list and TMF UK guide.

If you are listed: read the reason code

The reason code dictates the removal route. The 13 codes:

Code 06 reserved by Mastercard, not currently used. Active codes 01-05, 07-14 (13 total).

The dispute and removal evidence pack

Build code-specific. Send to the listing acquirer with your written dispute.

Code 14 (identity theft)

• Action Fraud (NFIB) report and reference number
• Photo ID and address proof for the rightful owner
• Evidence the listed identity was unlawfully assumed (correspondence, business filings)
• Police report if filed
• Witness statements

Code 09 (insolvency)

• Closure documentation from UK Insolvency Service
• Statement of all debts resolved
• HMRC clearance letter where applicable
• Liquidator's final report
• Companies House confirmation of dissolution or restoration

Codes 01, 02 (data compromise)

• Post-incident audit report
• Current PCI DSS compliance certificate
• Remediation log
• Evidence of breach closure
• Updated security policy

Code 12 (PCI non-compliance)

• Current PCI DSS compliance certificate, audited (Self-Assessment Questionnaire SAQ-D for non-trivial cases)
• Written remediation log addressing the original non-compliance findings
• Evidence of ongoing compliance monitoring

Submit the dispute to the listing acquirer

Written complaint format:

Subject: Formal Complaint, MATCH list dispute, account [previous-account-id]

To the [acquirer] complaints team,

I am writing to formally dispute the MATCH listing made against my business [name and registration]
on or around [date] under reason code [code]. The grounds for dispute are:

[State grounds: factual error, identity theft, resolved insolvency, PCI re-certified, etc.]

I attach the supporting evidence:
[List documents]

Please confirm receipt of this complaint within 5 business days, as required by PSR 2017.
I expect a final response within 8 weeks, after which I reserve the right to escalate to the
Financial Ombudsman Service.

Yours,
[Name]

FOS escalation

If the acquirer rejects the dispute or fails to resolve within 8 weeks, the Financial Ombudsman Service is the next route. Process:

1. Submit complaint at financial-ombudsman.org.uk with the full timeline and evidence pack.
2. FOS acknowledges within 5 business days.
3. Investigator initial assessment in 8-16 weeks.
4. If accepted, the acquirer must comply (binding on the acquirer if you accept the assessment).
5. If rejected by either party, full Ombudsman decision in another 4-12 weeks.

FOS can order: removal of the wrongful listing, fund release if held, plus compensation. FOS handles roughly 90,000 financial disputes a year; merchant-acquirer cases are a small but accepted fraction.

Trading while listed: high-risk acquirer route

If the dispute fails or the listing is justified, specialist UK high-risk acquirers will sometimes underwrite by reason code:

• Code 14 (identity theft, resolved): mainstream-tier underwriting available
• Code 09 (insolvency, resolved): high-risk pricing typical (3-5%)
• Codes 01, 02 (data compromise): case-by-case
• Code 12 (PCI): high-risk pricing post-remediation
• Code 04 (chargebacks): requires rolling reserve, 4-6% pricing
• Code 05 (fraud): hard; specialist underwriting only
• Codes 03, 07, 11, 13: rarely underwritten

High-risk pricing typically 3% to 6%+ blended, plus rolling reserve (5-15%), plus higher chargeback fees. See our high-risk verticals guide for the UK acquirer panel.

A note on identity-theft cases (code 14)

UK code-14 cases are the cleanest removal route in our experience because of the documentary trail Action Fraud creates. Steps:

1. File an Action Fraud report at actionfraud.police.uk. You get an NFIB reference number within 24-48 hours.
2. Attach the NFIB reference to the dispute letter to the listing acquirer.
3. Provide rightful-owner ID, address proof and any business filings showing the original ownership.
4. If the acquirer rejects, escalate to FOS with the same evidence.
5. FOS frequently orders removal in documented identity-theft cases.

Cross-link: related crisis runbooks

• Account-termination process: account-terminated runbook
• Held funds during termination: funds-frozen runbook
• Reference: MATCH list and TMF UK guide (full reason-code reference)