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Paper and phone authorization for ACH

Offline Authorizations

We understand that collecting your client’s payment authorization 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 authorization collection options. 

Before using these offline options, it’s important to be aware that there are strict compliance requirements that govern setting up authorizations in this way. There will be different requirements depending on the type of authorization. We have provided further information on this below. 

Please note that offline authorizations are only available to customers on our Pro and Custom pricing packages. Please see our Pricing page for more details.

Offline Authorizations Use Cases / Schedules

  Single Recurring Standing

Use cases

A one-off authorization to a one-time transfer of funds.

A regular debit for substantially similar amounts at scheduled intervals.

An advance authorization 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 (with respect to the authorization) is required by the customer. This is because each payment needs to be separately authorized under a new single debit authorization (i.e. the original authorization cannot be re-used).

No future action by the customer is required.

Future debits can only be initiated by the customer through further affirmative action. 

This action needs to: (1) be set out in the authorization (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 Frequency

Not Applicable. 

Each payment needs to be separately authorized under a new single debit authorization (i.e. the original authorization cannot be re-used).

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.

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.

Offline Authorizations Methods

Paper authorizations (PPD debit) 

Paper authorizations are a great alternative to an online authorization form if your clients do not have access to, or use of, a computer or other electronic device with sufficient internet access.

Process for collecting ACH authorization with a paper form:

  • Print the paper authorization form (note that there are some details which you might want to populate in advance - see our guidance here for more information).

  • Ask your customer to complete and sign the authorization form.

  • Ensure all fields are completed (see our guidance here for more information).

  • Set up the customer and offline authorization in GoCardless via the dashboard or API.    

  • Provide your customer with an electronic or paper copy of the completed authorization form.

  • Once you have set up a paper authorization, you must adhere to the following retention records (and you must provide a copy of these at the request of GoCardless): 

      • For single authorizations: You must retain the original or a copy of the authorization for TWO years from the date of the settlement or, if the authorization is revoked before the date of settlement, then for TWO years from the date of the revocation. 

      • For recurring authorizations: You must retain the original or a copy of the authorization for TWO years from the date of the authorization expires (if the authorization has an end date) or is revoked.

      • For standing authorizations: You must retain (i) the original or a copy of the authorization for TWO years from the date of the settlement or, if the authorization is revoked before the date of settlement, then for TWO years from the date of the revocation; and (ii); proof that the customer affirmatively initiates each debit under the standing authorization for TWO years from the date of settlement.

  • Remember, if your customer has set up a recurring authorization 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, you must provide your customer with 7 calendar days’ notice. 

  • Remember, if your customer has set up a standing authorization, 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).

Telephone authorizations (TEL debit) 

You can collect your customer’s details and obtain authorization over the phone using an approved transcript. This is particularly useful if you are speaking with your customers as part of your sales or onboarding flow.
Please note that the following guidance only applies to debit authorizations obtained from your customer via telephone and not via the Internet or a Wireless Network.

Process for collecting authorization over the phone:

  • 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. 

  • Conduct a phone call with your customer, to collect their details & obtain their authorization, using our approved script.

  • 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.).

  • Ensure all fields are completed - see our guidance here for more information.

  • Set up the customer and offline authorization in GoCardless via the dashboard or API.

  • Provide your customer with an electronic or paper copy of the completed authorization form: 

      • For single or standing authorizations, you are obliged to either record the customer’s oral authorization, OR prior to the first payment provide a written copy of the authorization (and you should tell the customer which method the notice will be provided e.g. email or post). If you are choosing to provide a written copy of the authorization, complete the paper authorization form with the details you’ve taken via the phone and send to the customer (via agreed method).

      • For recurring authorizations, you are obliged to record the customer’s oral authorization, AND prior to the first payment, provide a written copy of the authorization (and you should tell the customer which method the notice will be provided e.g. email or post). Complete the paper authorization form with the details you’ve taken via the phone and send to the customer (via agreed method).

  • Once you have set up an authorization, you must adhere to the following retention records (and you must provide a copy of these at the request of GoCardless):

      • For single authorizations: You must retain the original or a duplicate audio recording of the oral authorization, OR the original or a copy of the written notice confirming the customer’s oral authorization for TWO years from the date of the authorization.

      • For recurring authorizations: You must retain the original or a duplicate audio recording of the oral authorization, AND evidence that a copy of the authorization was provided to the customer for TWO years from the date of the authorization being terminated or revoked.

      • For standing authorizations: You must retain either the original or a duplicate audio recording of the oral authorization for TWO years from the date of the authorization being terminated or revoked, AND proof that the customer affirmatively initiated each debit under the standing authorization for TWO years  following settlement of the debit. 

  • When asking the customer if they authorize the ACH entry to their account, you must receive explicit consent - remember, silence does not equal consent. 

  • Remember, if your customer has set up a recurring authorization and you want to change the amount of the payments you must provide your customer with a minimum of 10 calendar days’ notice before the debit, or if you want to change the timings you must provide your customer with a minimum of 7 calendar days’ notice before the debit. 

  • Remember, if your customer has set up a standing authorization, you must seek their affirmative action (the type of action will be described during the phone call) before creating future payments (and record evidence of this).

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