For adult companies operating in today’s increasingly regulated digital landscape, maintaining compliance with card brand requirements is essential — not only to safeguard your operations but also to ensure a safe and transparent environment for users.
Mastercard’s AN 1956 standards and VISA’s Verified Identity and Risk Program (VIRP) requirements were introduced to set clear expectations around protecting users and the integrity of online commerce. They cover age assurance, content moderation, participant verification and more, and place significant responsibilities on merchants and payment service providers.
Prioritizing comprehensive identity verification, age assurance, content moderation, complaint handling and reporting systems is crucial for navigating these complex requirements effectively.
This article will break down key components of AN1956 and VIRP, exploring how merchants can address specific requirements to meet these mandates confidently and effectively while fostering trust within the payments ecosystem.
Mastercard: AN 5196
Mastercard’s AN 5196 standards target merchants offering adult content in non-face-to-face environments, such as online platforms. Introduced in 2021, these requirements aim to ensure the integrity of transactions and protect against illegal or unethical content distribution.
The requirements outlined by AN 5196 mandate that sites:
- Document age and identity verification for all people depicted and/or uploading content.
- Review content prior to publication to ensure compliance with Mastercard’s standards.
- Include a complaint resolution process that addresses illegal or nonconsensual content within seven business days.
- Provide an appeals process allowing any individual depicted in content to request removal of that content.
- Submit monthly compliance reports to their payment acquirers.
VISA Integrity Risk Program
In May 2023, Visa launched the Visa Integrity Risk Program, which established updated requirements for acquirers and their designated agents to assist “high integrity risk” merchants, including adult sites. These requirements establish a set of ecosystem controls, requirements and capabilities designed to detect, deter and remediate illegal activity in the Visa payment system.
The requirements outlined by VIRP mandate that sites:
- Implement mandatory age verification for both consumers and creators.
- Provide evidence on how they comply with age verification laws within their jurisdiction.
- Enhance content moderation practices, with stricter policies required for user-generated and studio-produced content.
- Obtain third-party consent from other individuals appearing in content.
- Include visible takedown request and complaint links.
Important Steps for Ensuring Card Brand Compliance
Navigating these compliance requirements is a complex but essential process for adult sites and other high-risk merchants. These mandates aim to ensure safety, legality and trust within the payments ecosystem, so leveraging appropriate safety technology can play a critical role in meeting these obligations. Here are some strategies that high-risk merchants should prioritize to make sure they are in alignment with these standards.
1. Content Provider Verification and Accountability
High-risk merchants can ensure robust, automated identity and age verification for content providers by integrating AI and identity document scanning technologies, as well as non-intrusive methods that leverage data a platform already has, such as an email, to determine age.
Merchants should also maintain records of compliance to monitor repeat offenders across platforms, as “network effect” solutions can help prevent previously flagged or banned providers from registering on other sites. This collaborative approach is similar to how acquirers and card brands are able to spot fraudulent patterns and compromised card details across their network, offering an additional layer of security.
2. Participant Verification and Consent
High-risk merchants should ensure that all persons depicted in the content have verified their identity and age, confirming that participants are over 18 before starting a stream or uploading a video.
Additionally, as part of this verification process, all participants — not just the content provider — must provide explicit consent to be depicted in the content and for the content to be uploaded or streamed.
Having a robust process in place for verifying the identity and consent of all content participants is essential for compliance with card brand mandates. Safety tech providers can further help by offering comprehensive documentation to demonstrate compliance during audits.
3. Content Moderation
Implementing advanced content moderation systems ensures compliance with card brand standards while maintaining platform safety. Hybrid models leverage global networks of moderation experts and AI tools to review and moderate user-generated content prior to publication. This enables merchants to block uploading of images or prerecorded videos, as well as automatically stop livestreams, when content is flagged that may be illegal or in violation of card brands’ standards, including toxicity and abuse violations such as violence, weapons or drugs.
4. Complaint Processes and Appeals
Merchants should implement accessible and efficient complaint resolution mechanisms that address complaints regarding content and allow individuals depicted in a video to request its removal. When users report content through platforms’ integrated safety solutions, human moderators review and verify these reports, rejecting inappropriate content and flagging it for removal. Again, leveraging the “network effect” amplifies the effectiveness of these efforts, ensuring that flagged content is removed across all merchants within a network.
5. Compliance Reporting
Transparent reporting tools empower merchants to demonstrate adherence to card brand requirements. Effective reporting should include dashboards summarizing the status of identity checks, age verifications and content moderation outcomes; detailed logs for acquirers showing all flagged content and the merchant’s response; and alerts to ensure merchants act on flagged issues. Regular reporting builds trust with acquirers and card brands, reducing the risk of penalties or operational disruptions.
Prioritizing comprehensive identity verification, age assurance, content moderation, complaint handling and reporting systems is crucial for navigating these complex requirements effectively. By integrating robust safety measures into their compliance strategies, adult sites and other high-risk merchants can meet card brand mandates and foster a safer and more trustworthy environment for users.
Gavin Worrall is VP of Global Strategic Partnerships at VerifyMy, a safety technology provider with a vision to provide solutions that safeguard children and society online. Spanning age assurance, identity verification, content moderation and consent management, VerifyMy seeks to offer frictionless, trustworthy solutions for online platforms to maintain their integrity, protect their reputation and safeguard their users. He can be reached at sales@verifymy.io.
