KYC/KYB renewal

Introduction

In addition to the initial KYC/KYB verification of users, Mangopay has regulatory obligations to conduct ongoing monitoring of its users and repeat the verification of users at regular intervals in time to ensure they remain legitimate.

The ongoing monitoring and verification processes are in line with Mangopay’s terms and conditions and are necessary to comply with EU anti-money laundering (AML) obligations.

Mangopay’s obligations are designed to protect your platform, your users, and Mangopay from the misuse of the financial system and potential emerging risks. For your platform, ongoing KYC/KYB renewal demonstrates to your users a commitment to risk-based due diligence, security, and trust.

Scope

Mangopay’s continuous KYC/KYB verification applies to OWNER users of all types:

• Natural Users
• Legal Users of all types: Business, Soletrader, Organization, Partnership

Mangopay’s user risk classification is a multi-factor assessment, updated over time to adapt to evolving risk and regulations, and is not communicated externally.

Rollout

During the rollout, downgrades for non-renewal will be grouped on a single date, December 1st, 2026, even if their KycRenewalDeadline is earlier than that date.

The first date a user can be downgraded as a result of non-renewal in 2026, is:

• December 1st, 2026 (2026-12-01)

For the rollout:

• Users scheduled for renewal-related downgrade on this date (December 1st, 2026), will have been assigned a KycRenewalDeadline date that is November 30th, 2026 (2026-11-30) – or earlier, and it may even be in the past.
• No matter how long before November 30th their KycRenewalDeadline actually is, they will not be downgraded until December 1st, 2026.
• A webhook notification will be emitted for these users before or on August 31st (90 days before November 30th)
• There is a new event type for these webhooks, USER_KYC_RENEWAL_REQUIRED, which your platform should set up as soon as possible to receive the UserId
• KycRenewalDeadline dates will be assigned before August 31st, and features to retrieve them will be released and communicated via the usual channels

After the rollout:

• The USER_KYC_RENEWAL_REQUIRED is emitted 90 days before KycRenewalDeadline
• In case of non-renewal, a user is downgraded the day after KycRenewalDeadline

Example post-rollout

The true 90-day notification system will take effect from the day after, December 2nd, 2026.

Example:

• A user is scheduled for renewal-related downgrade on December 2nd, 2026.

For this user:

• Their KycRenewalDeadline is the day before: 2026-12-01 (UTC)
• A USER_KYC_RENEWAL_REQUIRED webhook event notification will be emitted on September 1st (90 days before the KycRenewalDeadline), containing the UserId – provided you set it up
• To avoid downgrade, they must successfully complete their KYC/KYB verification before the end of 2026-12-01 (23:23, UTC timezone)

Thanks to the features being delivered, you will also before then be able to retrieve the user’s KycRenewalDeadline:

• In the Mangopay Dashboard, on the User’s page
• Via the GET View a User’s regulatory status endpoint
• In the KYC_RENEWAL_DEADLINE report, which will be available via the API or Dashboard

Renewal cycle

When a User is successfully KYC/KYB verified, indicated by their KYCLevel changing to REGULAR, Mangopay sets two dates.

• LastKycDate – The date of the User’s last successful KYC/KYB verification, when KYCLevel changed from LIGHT to REGULAR.
• KycRenewalDeadline – The date after which the User will be KYC/KYB downgraded, and their KYCLevel changed from REGULAR to LIGHT, unless they successfully complete the KYC/KYB verification process again.

These dates are both in format YYYY-MM-DD in the UTC timezone (which is the date-only format of ISO-8601).

Over the coming months, these dates will both be available via the API, in the Dashboard, and via a new report.

Notification of upcoming renewal

Mangopay sends a webhook notification 90 days before a KycRenewalDeadline.

The event type for the notification is USER_KYC_RENEWAL_REQUIRED and it contains the UserId (read more about integrating this webhook below).

You can use this notification to plan your own communications with the user to ensure they renew their KYC/KYB in time.

Process

The process for requesting KYC/KYB verification renewal is the same as the first time the initial verification.

The user must successfully complete the hosted KYC/KYB experience generated via POST Create an IDV Session.

The legacy API-only process relying on KYC Documents can also be used in the same way as for the first-time verification if your platform still has the API-based solution implemented. The hosted solution is becoming required for all platforms. Once in place it should be used for all users for both first-time verifications and renewals.

Unsuccessful verification attempts have no impact (the IDV Session’s Status must become VALIDATED before the end of the deadline).

Requirements

The requirements in terms of data and supporting documentation also remain the same for a renewal as they are for a first-time verification.

Outcomes

Before the end of the KycRenewalDeadline, the user has either successfully completed their KYC/KYB verification again, or they have not.

Renewal

If the User successfully completes a new hosted KYC/KYB session before the deadline, then there is no change in the Mangopay services available to them.

A successful renewal means that the IDV Session Status becomes VALIDATED before the end of the date indicated by KycRenewalDeadline.

In a renewal scenario, the User’s KYCLevel remains REGULAR (there is no change).

Notification of successful renewal

Mangopay sends a webhook notification to notify you of a renewal.

The event type for the notification is USER_KYC_RENEWED and it contains the UserId (read more about integrating this webhook below).

The event is emitted when a User whose KYCLevel is already REGULAR successfully completes a new IDV Session (meaning its Status becomes VALIDATED, or all requirements are met for the legacy KYC Document process).

When this event takes place, Mangopay also:

• Assigns a new KycRenewalDeadline in the future
• Updates the LastKycDate

With the new deadline, the cycle starts again.

Downgrade

If the User does not successfully complete a new hosted KYC/KYB session before the deadline, then they lose their KYC status and their Mangopay payment services are restricted.

In this scenario, they are downgraded:

• Their KYCLevel changes from REGULAR to LIGHT
• As a result, they will be unable to exceed the KYC/KYB limits in place – for example, request payouts
• The Status of the IDV Session (or KYC Document(s)) changes from VALIDATED to OUT_OF_DATE

The downgrade is performed at the end of the date indicated by KycRenewalDeadline.

Example:

• If a user’s KycRenewalDeadline is 2026-12-15
• Given they do not successfully complete KYC/KYB verification before the end of December 15, 2026 (23:23 UTC)
• Then after midnight (00:00 UTC), which is December 16, 2026, their KYCLevel will become LIGHT

Notification of downgrade

Mangopay sends a webhook to notify you of a downgrade.

The event type for the notification is USER_KYC_LIGHT and it contains the UserId (read more about integrating this webhook below).

The event is emitted when the User’s KYCLevel changes from REGULAR to LIGHT.

When this event takes place:

• The KycRenewalDeadline and LastKycDate remain unchanged

Managing KYC/KYB renewal

Dashboard

In the Mangopay Dashboard, you will be able to:

• See the KycRenewalDeadline and LastKycDate for any given user on their details page
• Generate the new KYC Renewal Deadline report
• Set up the webhooks below

Webhooks

Mangopay provides webhooks that you can implement to be notified of continuous KYC/KYB verification events.

The RessourceId on both webhooks is the UserId.

Once you receive a notification, you will be able to call the GET View a User’s regulatory status endpoint to retrieve the KycRenewalDeadline.

Regulatory endpoint

You will be able to retrieve the KycRenewalDeadline for any given UserId from the GET View a User Regulatory Status endpoint.

This endpoint will return two relevant fields in the KycInformation object:

API response example

A call to the GET View a User Regulatory Status endpoint will return the body below:

1
{
2
    "Id": "user_m_01KT4CVZE78R2WHC5CN3ZS0VH6",
3
    "ActionCode": "",
4
    "ScopeBlocked": {
5
        "Inflows": false,
6
        "Outflows": false
7
    },
8
    "KycInformation": {
9
        "LastKycDate": "2025-12-15",
10
        "KycRenewalDeadline": "2026-12-15"
11
    }
12
}

Report

Mangopay will also provide a report that your platform can use to obtain the KycRenewalDeadline of large numbers of users.

You will be able to filter the report by the KycRenewalDeadline to be able to retrieve upcoming deadlines.

The KYC Renewal Deadline report will be available from the Dashboard, as well as the POST Create a Report endpoint.

The KYC_RENEWAL_DEADLINE report will contain the following columns: