Our
experience

Card-to-card (C2C) service

We advised our client, a small payment institution on the legal, regulatory and operational aspects of implementing a card-to-card (C2C) payout service, enabling end-users to transfer funds directly to payment cards via the Visa and Mastercard card scheme infrastructure. The model relies on a third-party scheme-integrated provider with the partner, acting as the technical and regulatory enabler, while the client delivers the service through its own user interface and customer relationship layer.

Our work focused on defining the regulatory roles and contractual allocation of responsibilities. We also assessed and structured the Terms & Conditions (T&C) governing the service, ensuring that the client obtains proper acceptance from users via a clearly presented, opt-in checkbox mechanism, with the agreement delivered on a durable medium (e.g. email) upon first use.

We also reviewed the technical flow, user interface language, and marketing aspects to ensure clarity in distinguishing card-based payouts from traditional bank transfers. Our involvement helped align the product with regulatory expectations while preserving a smooth and user-friendly experience.