ACH offline mandate

(Debit Authorisation) - merchant guidance

We understand that collecting your customer’s payment authorisation via an online form isn’t always possible, or doesn’t match how you would normally interact with your customers.

To help with this, we offer paper and phone authorisation collection options in the United States (ACH). Before using these options, it’s important to be aware that there are compliance requirements that govern setting up authorisations in this way. So, please carefully follow the relevant process and guidance below.

ACH authorisation use cases/schedules

Before getting started with the paper and phone collection options, we have set out below the three types of ACH authorisation that your customer can set up - single, recurring, and standing.

	Single	Recurring	Standing
Use cases	A one-off authorisation to a one-time transfer of funds.	A recurring debit at regularly scheduled intervals.	An advance authorisation for future debits initiated by a customer’s affirmative action.
Examples	Paying an initial upfront charge to join a gym.	Paying a regular monthly utility bill.	Paying for actions taken via a brokerage account.
Amount	Can be any set amount.	Can be any set amount, or a pre-agreed reasonable range (for it to be “reasonable” it should generally be commensurate with the goods/services being purchased e.g. it would not be reasonable to ask your customer to authorize a $10-$10,000 range for a phone bill).	Amount can change each time, but it will need to be agreed via your customer’s affirmative action (see “future action by customer”).
Frequency	One-off payment.	Regular timing (e.g. weekly, monthly, quarterly).	Irregular timing - as with the amount, it will need to be agreed via your customer’s affirmative action (see “future action by customer”).
Future action by customer	No future action is required by the customer to initiate the debit.	No future action by the customer is required to initiate the debit.	Future debits can only be initiated by the customer through affirmative action - this action needs to: (1) be set out in the authorisation (i.e. your customer has to know in advance what action they have to take); and (2) be taken by the customer (e.g. by placing an order with the merchant). An affirmative action cannot be no action.
Changes to Amount or Timing (Frequency)	Not Applicable - the amount and timing of an executed authorisation cannot be changed. If change is necessary, the customer needs to terminate the existing debit authorisation and execute a new one.	If the amount differs from the last debit, or from the pre-agreed amount / range, you must provide your customer with a minimum of 10 calendar days' notice before the debit. If the timings differ from the pre-agreed date / frequency, you must provide your customer with a minimum of 7 calendar days' notice before the debit. All merchants must provide these notifications, i.e. regardless of whether you have enabled custom notifications).	Not Applicable - future debits can only be initiated by the customer through further affirmative action. Both the amount and timing of the debit is driven by the customer’s affirmative action.
Notifications	Where we have a valid customer email address, GoCardless will provide your customer with notification, on or before the payment date, that a payment is due. If you have custom notifications enabled on your GoCardless account, or have not been able to collect a valid customer email address, you will be responsible for providing customer notifications.

Paper authorisation (PPD debit)

Paper authorisation forms are a great alternative to the online authorisation form if your customers do not have access to, or use of, a computer or other electronic device with sufficient internet access.

Paper authorisation & merchant guidance

You can find a copy of the paper form and the paper form guidance below:

Paper form

Paper form guidance

Process for collecting ACH paper authorisation:

Print the paper authorisation form (note that there are some details which you might want to populate in advance - see our paper authorisation form guidance for more information)
Ask your customer to complete and sign the authorisation form - ensure all fields are completed
Provide your customer with a non-changeable electronic (e.g. scanned) or paper copy of the completed authorisation form
Set up your customer in your GoCardless account
There are three basic steps to setting up a customer in GoCardless, which must be completed in the following order:
1. Create the customer record
2. Add the customer’s bank account details
3. Create a mandate against that bank account
The precise method you use to do this will be determined by how you've chosen to use GoCardless - via an API integration, using the GoCardless dashboard, or using a partner application. Please follow the relevant guidance linked below:
- Create a mandate via the GoCardless API
- Create a mandate using the GoCardless dashboard
- Create a mandate using a partner application - how you set up a customer and create a mandate will be dependent on the functionality available to you within the partner application you’re using
Keep a non-changeable electronic (e.g. scanned) or original paper copy of the completed authorisation in your own records for the following periods (you must provide a copy of these at the request of GoCardless):
- Single authorisations: two years from the date of the settlement or, if the authorisation is revoked before the date of settlement, then for two years from the date of the revocation
- Recurring authorisations: two years from the date of termination (if the authorisation has a predetermined end date), or for two years from the date of revocation
- Standing authorisations: two years from the date of termination (if the authorisation has a predetermined end date), or for two years from the date of revocation (in addition to the electronic or paper copy of the authorisation, you must retain proof that the customer affirmatively initiated each debit under the standing authorisation for two years following settlement of the debit)
Remember, if your customer has set up a recurring authorisation and you want to change the amount of the payments you must provide your customer with 10 calendar days’ notice, or if you want to change the timings (frequency), you must provide your customer with 7 calendar days’ notice
Remember, if your customer has set up a standing authorisation, you must seek their affirmative action (the type of action will be set out on the paper form they signed) before creating future payments (and record evidence of this)

Phone authorisation (TEL debit)

You can collect your customers' details over the phone using an approved transcript to obtain authorisation to set up an ACH authorisation on their behalf. This is particularly useful if you are speaking with your customers as part of your sales or on-boarding flow.

Please note: The following guidance only applies to authorisation obtained from your customer via the phone and not via the Internet or a Wireless Network.

Process for collecting ACH phone authorisation:

Please note: You must have an existing relationship with the customer OR, if there is not an existing relationship, the customer must have initiated the telephone call to you. You will be considered to have an existing relationship when either:

There is a written agreement in place between you and the customer for your provision of goods and services, or
The customer has purchased goods or services from you within the past two years

You will NOT be considered to have an existing relationship on the basis of an existing relationship between the customer and one of your affiliates.

You are required to establish and implement procedures to verify the identity of the customer (e.g. verifying against directories and databases, or pertinent information such as caller ID information, secret answers, etc.)

Download a copy of our approved transcript
Use this transcript to collect your customers’ details and obtain their authorisation over the phone
When asking the customer if they authorise the ACH entry to their account, you must receive explicit consent - remember, silence does not equal consent
Once you have all of the required information, you should populate that into our paper authorisation form (see above)
Provide your customer with a non-changeable electronic (e.g. scanned) or paper copy of the completed authorisation form:
- For single or standing authorisations, you are obliged to either record the customer’s oral authorisation, OR prior to the first payment provide a written copy of the authorisation (and you should tell the customer which method the notice will be provided e.g. email or post)
- For recurring authorisations, you are obliged to record the customer’s oral authorisation, AND prior to the first payment, provide a written copy of the authorisation (and you should tell the customer which method the notice will be provided e.g. email or post)
Set up the customer in your GoCardless account
There are three basic steps to setting up a customer in GoCardless, which must be completed in the following order:
- Create the customer record
- Add the customer’s bank account details
- Create a mandate against that bank account
The precise method you use to do this will be determined by how you've chosen to use GoCardless - via an API integration, using the GoCardless dashboard, or using a partner application. Please follow the relevant guidance linked below:
- Create a mandate via the GoCardless API
- Create a mandate using the GoCardless dashboard
- Create a mandate using a partner application - how you set up a customer and create a mandate will be dependent on the functionality available to you within the partner application you’re using
Once you have set up a phone authorisation, you must adhere to the following retention records (you must provide a copy of these at the request of GoCardless):
Single authorisations: retain the original or a duplicate audio recording of the oral authorisation, OR the original or a copy of the written notice confirming the customer’s oral authorisation for two years from the date of the authorisation
- For recurring authorisations: retain the original or a duplicate audio recording of the oral authorisation, AND evidence that a copy of the authorisation was provided to the customer for two years from the date of the authorisation being terminated or revoked
- For standing authorisations: retain either the original or a duplicate audio recording of the oral authorisation for two years from the date of the authorisation being terminated or revoked, AND proof that the customer affirmatively initiated each debit under the standing authorisation for two years following settlement of the debit
Remember, if your customer has set up a recurring authorisation and you want to change the amount of the payments you must provide your customer with 10 calendar days’ notice, or if you want to change the timings (frequency), you must provide your customer with 7 calendar days’ notice
Remember, if your customer has set up a standing authorisation, you must seek their affirmative action (the type of action will be set out on the paper form they signed) before creating future payments (and record evidence of this)