Why Your MIDs Keep Getting Shut Down — And The 2025 Blueprint To Staying Live, Scaling Volume, And Running Rebill Offers Safely

Why MIDs Keep Getting Shut Down

Processors shut down merchants because of regulatory liability, bank exposure, and card-brand monitoring—not because of your product. The three triggers that almost always cause termination are:

• High chargebacks (Visa/MC thresholds)
• Misleading or non-compliant trial/rebill flows
• Traffic quality issues from TikTok, Facebook, or affiliates
• Missing disclosures or incomplete terms pages
• Bank fear of FTC actions (common in supplements and yes, hemp)

The Actual Laws That Cause MID Terminations

Here are the real laws used in enforcement actions against merchants running trials, rebills, supplements, and aggressive funnels:

1. FTC Restore Online Shoppers’ Confidence Act (ROSCA)

15 U.S.C. §§ 8401–8405 This law governs free trials, negative-option billing, continuity programs, and subscriptions. Your trial must:

• Obtain “express informed consent” before charging
• Disclose all terms “clearly and conspicuously”
• Provide a simple cancellation method

2. FTC Negative Option Rule (16 CFR Part 425)

Updated in 2024–2025. Requires:

• Clear upfront disclosures of recurring billing
• Affirmative consent separate from other checkboxes
• Easy one-click or one-step cancellation

3. FTC Act Section 5

Bans “unfair or deceptive acts or practices.” This covers:

• Fake scarcity timers
• Fake reviews
• Inflated health claims
• Hiding the price or rebill terms

4. Visa + MasterCard Enforcement Rules

Visa and MC enforce their own rules **separate from US law**. Violating these can shut your MID down instantly.

Visa Trial/Subscription Rules (2020–2024 update, still in effect):

• Clear subscription terms on the checkout page
• Email receipt immediately after the first charge
• Free trials must send a reminder email 7 days before billing
• Easy cancel link required

MasterCard Excessive Chargeback Program (ECP):

• Merchants over 1% chargebacks are terminated
• High-risk verticals get even tighter windows

5. CARD Act — “Clear Terms Before Billing”

Requires consumer clarity before authorizing recurring charges. Banks use this to justify shutting down unclear trial funnels.

The Blueprint for Staying Live in 2025 (Real Compliance Steps)

1. Put Your Rebill Terms Above the Fold

Visa and ROSCA both require “clear and conspicuous” placement. That means:

• Not hidden under the fold
• Not hidden behind a link
• Not small text or low-contrast fonts

2. Use a Separate Checkbox for Recurring Billing

Required under FTC’s updated Negative Option Rule. The checkbox cannot be pre-checked.

3. Add a Timer-Free Checkout Page

FTC has cracked down on countdown timers and fake urgency. (Example: FTC v. Triangle Media, FTC v. AH Media)

4. Send Reminder Emails 7 Days Before Billing

Visa’s subscription regulations require a reminder email before the rebill hits.

5. Implement Legitimate Cancellations

FTC requires cancellations to be:

• Simple
• Immediate
• Available in the same medium used to sign up

6. Keep Chargebacks Under 0.9%

Over 1% = MID terminated Over 2% = placed into Visa Fraud Monitoring Program Over 3% = bank forced closure

7. Use a Processor That Understands Aggressive Funnels

High Wire Payments keeps merchants live because underwriting matches your funnel to the correct bank and monitors compliance in real-time.

2025 Compliance Requirements for Trials, Rebills & High-Volume Offers

1. Place all billing terms at the top of the checkout page
2. Use a dedicated checkbox for recurring billing
3. Avoid fake scarcity or fake “social proof” widgets
4. Use real testimonials with documentation
5. Send immediate receipts + 7-day subscription reminders
6. Offer instant cancellation (email + page + phone)
7. Store IP address, timestamp, and consent logs
8. Use bank-approved fulfillment timelines
9. Maintain full COA, labeling, and refund policy compliance

Following these requirements keeps your MID stable, protects you from FTC action, and dramatically reduces chargebacks.

FAQ — Staying Live in 2025