High-risk merchant account for telehealth providers with a Maltese company

Our process begins with a detailed review of your telehealth model. We analyse your clinician licensing, patient verification methods, and the types of services offered, mapping them to the correct Merchant Category Code (MCC), typically 8099 or 8011. We assess your processing history, paying close attention to chargeback and refund ratios, especially for subscription-based care models which can be a focal point for underwriters.

Next, we build a complete underwriting file. This is not just a collection of documents; it is a narrative that explains your business to our acquiring partners. For a Maltese entity, this file includes your certificate of registration, M&A, and beneficial ownership records, alongside your operational documents. We conduct a thorough review of your website to ensure it meets the stringent compliance standards of card networks, including clear display of your refund policy, privacy policy, and a compliant payment descriptor to minimise chargebacks.

With the file prepared, we identify and approach the most suitable acquirers from our network. We focus on EEA-licensed institutions with a proven appetite for regulated sectors like telehealth. We manage the warm introduction, handle the initial underwriting questions, and streamline the Q&A process, ensuring your application is assessed efficiently. Our involvement continues post-approval, helping you set up appropriate settlement accounts and monitor your processing activity to maintain a healthy relationship with your provider.

Underwriters are primarily concerned with four areas: regulatory compliance, chargeback risk, financial stability, and the legitimacy of the beneficial owners. For a telehealth provider, their scrutiny is intense.

First, they will verify your clinical credentials. This involves checking the licences of your practitioners in every jurisdiction you serve. They will request copies of these licences and may perform independent verification. Your prescribing policy and data protection policy are also key documents; underwriters need to see that you operate within legal and ethical boundaries, especially concerning patient data (in line with GDPR) and the dispensing of medications.

Second, they analyse your processing history. You will be required to provide at least six months of processing statements. Underwriters will calculate your chargeback and refund ratios themselves. They look for stability and predictability. Any spikes will require a detailed explanation. If you have no prior processing, they will scrutinise your business plan and financial projections to assess potential risk.

Third, your Maltese corporate structure will be examined. Underwriters expect a clear and transparent ownership structure. They will cross-reference the Malta Business Registry data you provide. They need to be confident that the business is not a shell company and that the ultimate beneficial owners (UBOs) and directors are fit and proper. This involves KYC checks, including identity verification and checks against sanctions lists.

Finally, they will perform a full review of your website and patient journey. They test the clarity of your terms of service, the checkout process, and your customer support channels. They need to see that a patient can easily understand what they are paying for and how to cancel or request a refund.

Using a Maltese company provides both advantages and specific challenges for payment processing. As an EU member state, Malta offers a credible base for serving European and international customers. A Maltese entity has access to a wide range of EEA-licensed payment institutions, which is crucial as local Maltese banks are notoriously conservative and generally do not provide merchant acquiring for high-risk industries.

However, the jurisdiction also brings scrutiny. The Malta Financial Services Authority (MFSA) and the Malta Business Registry maintain high standards of corporate governance. Acquirers expect Maltese companies to have demonstrable substance. While full office and staff might not be necessary for every telehealth model, your business must be managed and controlled appropriately. A simple letterbox company is a major red flag for underwriters. You must maintain proper records, file audited annual accounts, and keep your beneficial ownership information up to date.

For currency, operating from Malta naturally centres on the EUR. You will be able to process payments and receive settlements in EUR seamlessly. If you need to process in other currencies like GBP or USD, this is typically handled by your acquirer, who will apply a conversion rate for settlement into your corporate account. Most of our telehealth clients using Maltese entities choose to hold their funds in a multi-currency account with an EU-based EMI or payment institution rather than a traditional Maltese bank, allowing for greater flexibility and faster access to funds.

Compared to a jurisdiction like Hong Kong, Malta provides a more straightforward route to EU acquiring relationships, which is often essential for telehealth businesses targeting European patients.

Telehealth merchant accounts are frequently declined for reasons that are often avoidable. A primary cause is a mismatch between the business model and the acquirer's risk appetite. Many providers apply to mainstream acquirers or platforms like Stripe or PayPal, which are not equipped for high-risk MCCs like 8099 (Medical Services) and will decline the application or terminate the account soon after it goes live.

Another common reason for rejection is an incomplete or poorly prepared underwriting file. This includes failing to provide clear evidence of clinician licensing for all jurisdictions served, having an inadequate data protection policy, or operating a website that is not fully compliant with card scheme rules. Underwriters see these gaps as indicators of a higher risk of regulatory issues and chargebacks down the line. Vague or evasive answers during the underwriting Q&A process also raise immediate red flags.

Our file preparation process is designed to pre-empt these issues. We ensure your clinician licences are presented clearly, your policies are robust, and your website meets all compliance checkpoints before an acquirer ever sees the file. We also flag any business activities Xavion cannot support, such as placing pharmacies that do not require prescriptions or facilitating the sale of controlled substances without the necessary, specific licences.

Finally, accounts are often closed due to post-approval issues, primarily excessive chargebacks. Our work is not done at approval. We guide you in setting up effective chargeback prevention measures, such as clear billing descriptors and responsive customer service, and help you monitor your ratios to stay within the acquirer’s accepted thresholds.

For a well-prepared telehealth business using a Maltese entity, the typical timeline from submitting a complete underwriting file to our acquiring partners to receiving a live merchant account is between two and six weeks. This timeframe is indicative and can be influenced by the complexity of your model and the acquirer's current workload. The most common cause of delay is an incomplete file, which is why our initial preparation phase is so critical.

Once the application is submitted, the acquirer's underwriting team will conduct their due diligence. There may be a round of questions where they seek clarification on your business model, licensing, or compliance procedures. Our team manages this communication, ensuring your responses are prompt and precise to keep the process moving forward.

Going live is just the beginning. Maintaining a healthy merchant account requires ongoing diligence. The first 90 days are a crucial monitoring period for the acquirer. You will need to keep your chargeback and refund rates well below the thresholds set by the card networks (typically under 1%). This involves diligent customer service, clear communication with patients, and potentially using chargeback mitigation alerts.

We advise clients to be prepared for regular reviews from their acquirer, which may occur every six to twelve months. They will look at your processing volumes, chargeback ratios, and any changes to your business model. By maintaining good records and a proactive approach to compliance, you can ensure a stable, long-term processing relationship.