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Introduction

Mangopay is updating its rules on the Payer category of users to enhance security for your platform and comply with regulatory requirements.

These changes aim to provide a safer experience for all users.

This page outlines the rules that are being enforced to bring consistency with the user categorization that is already in place.

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Categories

The rules are based on Mangopay’s user categories: Payer and Owner.

Your platform categorizes all users – Natural and Legal (of all types) – into one of two groups:

  • Payer – A Natural User or Legal User whose UserCategory is PAYER. The Payer category of user only requires basic information (e.g. name, email address). The Payer category is designed to register individuals or businesses making pay-ins on your platform using a Mangopay payment method.
  • Owner – A Natural User or Legal User whose UserCategory is OWNER. The Owner category of user requires more detailed information (e.g. date of birth, country of residence), and requires the user to accept Mangopay terms and conditions. The Owner category is designed to register and identify individuals and businesses that are receiving funds from other users, and who can request KYC verification and, once verified successfully, payouts to an external bank account.

An Owner can do everything a Payer can do. Once a user is an Owner, they cannot revert back to the Payer category.

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Note about PLATFORM category

There is a third value for UserCategory, PLATFORM, which represents the platform integrating Mangopay in their app or website. Depending on the platform’s implementation, this value may be assigned to a single user by Mangopay as part of the approved and validated workflow.

The PLATFORM value:

  • Can only be applied by Mangopay
  • Is only applied to one user per platform (one per ClientId)
  • Requires the user to have UserCategory of OWNER and be KYC verified (KYCLevel is REGULAR)

The PLATFORM category of user is not affected by the rules being applied to the PAYER category.

If your platform has a user that should be categorized as the PLATFORM but isn’t, then please contact Support via the Dashboard.

In addition to the PLATFORM user, there are other approved and validated users in place for technical in certain approved workflows. These technical users should not be affected by the restrictions being introduced for PAYER users, either because they do not breach them or because they are categorized as OWNER. If your platform has any queries about technical users, please contact Support via the Dashboard.

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What your platform needs to do

The restrictions being introduced aim to comply with regulations and provide a safer experience for all your users.

All platforms should review and familiarize themselves with the restrictions below.

You may be required to change your integration to align with the restrictions, but the exact steps required will likely depend on your existing integration.

In many cases, you may need to categorize a set of users as OWNER. SCA is being introduced on the act of categorizing a PAYER as an OWNER, as described in SCA on Users. However, it is still possible to categorize users as OWNER via the legacy endpoint and via the Dashboard. In this case, the OWNER must later be enrolled in SCA separately.

In other cases, a more significant change in your integration may be required to align your usage with the restrictions below. We invite you to familiarize yourself with the features impacted by the rules below, consulting the rest of our documentation for the current integration standards. Please contact Support via the Dashboard if you require confirmation on any matter or have a query.

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Restrictions being introduced

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UserCategory parameter is mandatory on POST and PUT calls

The UserCategory parameter is required on all API calls to create (POST) or update (PUT) a user. While Mangopay policy already requires categorization, the change is being enforced technically.

API calls to the POST or PUT endpoints that don’t contain UserCategory will return an error.

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Transfers can’t be credited to wallets owned by Payers

Users with UserCategory of PAYER are not allowed to receive transfers from other users. However, PAYER users are permitted to transfer funds between wallets belonging to them. PAYER users can also receive transfer refunds (and pay-in refunds).

Requests to POST Create a Transfer endpoint where the owner of the CreditedWalletId is a PAYER (and not also the owner of the DebitedWalletId) will fail with the ResultCode 002701.

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Payouts can’t be debited from wallets owned by Payers

Payouts can’t be debited from wallets owned by Payers except when the PaymentRef parameter is provided on the POST Create a Payout endpoint, with the ReasonType set to PAYIN_REFUND and the Id of the initial pay-in as the ReferenceId. For more information, see Refunds using payouts.

Otherwise a request to POST Create a Payout endpoint will result in a failed payout with the ResultCode 002701.

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KYC Documents and UBO declarations can’t be submitted for Payers

Payers are not able to request KYC verification (by submitting one or more KYC Documents). For Payers, a request to PUT Submit a KYC Document will result in the document Status being set to REFUSED and a KYC_FAILED event.

Note – If a KYC document is requested for a Payer, they will be able to send it

Mangopay conducts routine pay-in screening for anti-fraud purposes as part of it’s regulatory obligations as an EMI.

In some cases, Mangopay may request an ID document or proof of address from a Payer as part of this process, which must be submitted as a KYC document via the API or Dashboard. If this happens, there will be no restriction for the Payer to submit the document.

Payers are not able to declare beneficial owners in a UBO Declaration. If the user is a Payer, the POST Create a UBO Declaration endpoint will return an error: