Being treated as a high-risk business by a payment provider can already make onboarding more complex, but getting rejected when applying for a high-risk merchant account is probably a whole other experience.
Before you apply for a high-risk merchant account with an EEA provider, it is worth understanding what usually goes wrong and why businesses in the same industry can receive different outcomes. The quality of their documentation can make a difference, but providers also consider factors such as ownership, operating countries, processing history, transaction volumes and the overall business model.
Many factors can improve or weaken your application.
A number of core checks are common across reputable providers, even though the exact requirements and requested documents can differ depending on the business and its risk profile.
In this article, our team will explain how merchant onboarding usually works in the EEA and how to pass the high-risk merchant approval in the EEA.
Why high-risk merchant underwriting in the EEA is so strict
The European Economic Area operates under PSD2, while PSD3 and the accompanying Payment Services Regulation are being introduced to update the current framework. Together, they set rules for payment institutions, transaction authentication, fraud prevention, and liability.
Anti-money laundering rules require providers to apply risk-based due diligence before a business gets a merchant account. Some companies fall under the high-risk category. For instance, adult content, nutraceuticals, and subscription models with high refund rates may face stricter checks because of provider policies, card-scheme rules, and chargeback exposure.
Chargeback history and ratio are also very important when assigning the risk category. However, providers also consider the merchant’s industry, business model, financial position, fraud exposure, and overall compliance setup. A low chargeback ratio does not automatically make an otherwise unsupported industry acceptable.
The Digital Operational Resilience Act (DORA), enforced since January 2025, adds another layer to the issue. It has operational resilience requirements that make banks and EMIs assess technology, cybersecurity, system capacity, and third-party ICT risks more carefully.
Put those three together, and you get high-risk merchant approval (EEA) decisions that take weeks instead of days.
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The four core pillars underwriters evaluate
Every high-risk merchant approval in the EEA review, regardless of provider, comes down to four things underwriters check independently before anyone signs off.
Business model viability and processing history
Before any merchant account gets approved, an underwriter wants to see how your business behaves in the wild, not what your application says about it. In simple terms, whether you belong to the regular category, high-risk, or are completely unsuitable for cooperation is heavily influenced by this review, although your industry, compliance setup, ownership structure, operating markets, and the provider’s risk appetite also matter.
It means:
Average transaction value, and how it compares to the vertical norm (industry standard).
Monthly processing volume, and whether it’s trending up, flat, or volatile.
Chargeback and refund ratios – providers compare these against their own risk limits and the relevant card-scheme monitoring rules. There is no single industry-wide cutoff at 0.9% or 1%, and exceeding that level does not automatically mean that every provider will reject you.
For example, Visa’s current VAMP calculation combines reported fraud and disputes rather than measuring chargebacks alone. Its excessive merchant threshold in the EU was reduced to 1.5% in April 2026 and also includes a minimum monthly count requirement. Mastercard applies separate monitoring rules and calculations.
This is where chargeback history verification can become a make-or-break step if you already have processing history. If you do not have any, underwriters will rely more heavily on your business model, projections, financial position, and risk controls.
Underwriters often ask for recent processing statements, commonly covering several months, from your current or previous provider, then cross-reference those numbers against whatever you’ve claimed in your application. The exact period is set by the individual provider, so it will not always be 3–6 months. Previous transaction volumes and chargeback rates are commonly reviewed during merchant onboarding.
Inconsistencies here will slow everything down, or even kill the entire application.
The compliance co-review: where risk and compliance teams examine the same application
You might assume that “underwriting” is one team doing one review like regular onboarding. However, it is not always the case. In Europe, high-risk applications are often reviewed by more than one team, depending on the payment provider’s internal structure and the level of risk involved.
The compliance co-review can involve a risk analyst and a compliance officer assessing different parts of the same file, then comparing their findings before the application is approved.
The risk analyst is looking at financial exposure – processing volume, chargeback trends, concentration risk – all the usual business-related information.
The compliance officer is looking at something different: is this business licensed to operate in the jurisdictions it’s targeting? Does it have connections to a sanctioned person, entity, or organization? Is there a politically exposed person anywhere in the ownership structure or a known close associate connected to the business relationship?
A compliance co-review that flags even one unresolved item – an expired gambling license in one EU member state, an unclear UBO structure, or a UBO connected to a sanctioned person or entity – pauses everything until it’s cleared.
The dual-track approach can be slower than single-reviewer underwriting. Still, the additional checks can give licensed providers greater confidence when deciding whether and how to support high-risk merchants.
Corporate ownership and financial standing
Ownership transparency isn’t optional under current EEA anti-money laundering rules – any natural person who ultimately owns or controls the business must be identified and verified. Direct or indirect ownership of 25% plus one share, or more than 25%, is one indicator, but control can also be established in other ways. Relevant owners and controllers are also screened for sanctions and PEP status.
UBO verification (Ultimate Beneficial Owner)can be rather slow. Especially if you’re a founder with a layered corporate structure (holding companies, nominee shareholders, offshore parent entities). In cases such as this, providers need enough documentation to trace ownership and control through every layer.
On top of ownership, underwriters often want proof the business itself is financially sustainable: recent bank statements, evidence of working capital, and – for newer companies – a credible explanation of how the business is funded.
Website, checkout flow, and operational compliance
The last pillar has nothing to do with the balance sheet and everything to do with what a customer sees when they land on your checkout page. Website problems can be a major reason for delays or rejection.
Underwriters will often manually review your site for:
A refund policy that matches what you’ve claimed in your application
Terms of service and a privacy policy that reference the correct legal entity
A checkout flow that clearly discloses pricing, subscription terms, and recurring billing
Working contact details and a support channel customers can actually use
A billing descriptor that customers cannot clearly connect to your trading name or business, or a refund policy that contradicts your terms of service, can raise a serious flag – regardless of how clean your financials are.
A practical EEA high-risk merchant underwriting checklist
Every EEA provider phrases it differently, but many of the core documents requested during merchant underwriting are similar across the market. The exact merchant underwriting checklist will still depend on the provider and legal regulations in the country.
Here’s the merchant underwriting checklist to consider you apply – not after an underwriter asks for it.
Corporate verification
Certificate of Incorporation or an equivalent company registration document;
Memorandum and Articles of Association where applicable;
Register of Directors and Shareholders or equivalent official ownership and directorship records.
Identity and ownership (UBO verification)
Passport or ID copies for UBOs and any directors, signatories, or representatives the provider needs to verify;
Proof of address for the relevant individuals, using a document that meets the provider’s freshness requirements.
Financial and processing records
Underwriters build a large part of chargeback history verification from what’s in this section, so precision matters more here than almost anywhere else in the file;
Recent processing statements, often covering 3–6 months, showing payment volumes, refunds, and chargebacks, if you have previous processing history;
Recent business bank statements.
Important note: do not confuse them during the EEA merchant onboarding: processing statements show your payment-processing activity, including refunds and chargebacks, while bank statements show the activity and financial position of your business bank account.
Operational and licensing proof
Valid operating licenses where applicable (gambling, financial services, etc.)
A secure, working processing domain and checkout flow, including valid HTTPS/SSL
Supplier or fulfillment evidence (contracts, invoices, or shipping arrangements), especially for e-commerce, dropshipping, and other businesses that depend on third-party suppliers or delayed fulfillment
Underwriters can ask for more depending on your industry and country of origin. For example, iGaming operators should expect additional licensing documentation per jurisdiction, e-commerce companies may need to provide additional supplier, inventory, or fulfillment evidence, and companies with layered ownership structures should expect deeper UBO requests.
Payment providers that support your industry want the application process for the EEA merchant onboarding to go smoothly – help them by getting these documents right beforehand.
How to prepare your file for a smoother approval process
Eliminating red flags before submission
Before you submit anything, check all the documents and click through your own checkout flow the way a first-time customer would. If everything is good, you can submit your application.
There are many rules and regulations in any country – you are not obliged to know everything, so don’t be shy about asking the provider’s onboarding or customer support team to clarify its requirements. You can even do it before you apply.
Streamlining UBO identification
If your corporate structure has more than one layer – a holding company, a parent entity in a different jurisdiction, nominee arrangements – build a visual ownership chart before you apply.
It is one of the most useful additions to your merchant underwriting file. Underwriters may need to trace ownership and control through every layer to identify the natural persons who ultimately own or control the business.
How Genome simplifies high-risk merchant onboarding
Tailored high-risk merchant accounts
We at Genome built our onboarding process with streamlining in mind, as we understand that a lengthy onboarding process can be very stressful.
Genome treats applications from licensed iGaming operators, SaaS platforms, digital services providers, and other businesses with thorough care, and our experienced team knows how to handle the required checks efficiently.
Beyond merchant onboarding, we can provide an integrated financial platform designed for European businesses, as well as low- and high-risk merchant accounts.
Our pricing for both low-risk and high-risk companies is transparent and displayed on dedicated pricing pages on our website. Final pricing and eligibility depend on the results of due diligence and compliance checks.
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All-in-one financial management ecosystem
Getting approved is the first step, not the finish line. Genome business account users can open multi-currency business accounts in 12 currencies: EUR, USD, GBP, PLN, CHF, JPY, CAD, CZK, HUF, SEK, AUD, and DKK.
They can also access Open Banking payments (Pay by Bank), which avoid card-network chargebacks because the payments do not run through card networks. Instead, merchants receive instant bank payments via SEPA Instant and Credit. Card payment processing is coming soon as well. Genome’s corporate Visa cards can be used for team expenses and ad spend.
Batch payout tools for businesses are also a popular feature – they allow companies to pay affiliates, creators, suppliers, and other recipients at volume. Our whole business is to be a stability pillar for our clients.
Start your EEA high-risk application today
A smoother high-risk merchant approval in the EEA depends on several factors, including documentation that’s actually ready, transparent ownership, and an underwriting process supported by clear communication.
Genome is a natural place to start. Open a Genome business account and submit your documentation directly to a team experienced in reviewing high-risk merchant onboarding applications. Approval and access to individual services remain subject to eligibility, due diligence, and compliance checks.
