Provision record
Mercury · Mercury Terms of Service · View original document ↗

Invoice Payment Holds at Mercury's Sole Discretion

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Document Record

What it is

Mercury applies a discretionary hold of one, two, or four business days on incoming ACH invoice payments before crediting funds to the merchant's account, with the hold period determined solely by Mercury based on undisclosed risk factors. Estimated availability dates are not guaranteed and may change, and Mercury reserves the right to modify hold policies at any time without specifying a notice requirement.

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This analysis describes what Mercury's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

This provision establishes that merchants using Mercury Invoicing cannot rely on specific funds availability timelines, as hold periods are set by Mercury at sole discretion and estimated availability dates are explicitly not guaranteed. Mercury also reserves the right to modify hold policies at any time, creating ongoing operational uncertainty for merchants managing cash flow based on invoice payment schedules.

Recent Activity

This document changed recently

Medium Jun 26, 2026

Mercury's updated terms establish detailed rules for how recurring autopay works on invoices. Under the revised language, payers authorize recurring ACH debits through a separate addendum, Mercury will not retry failed payments (except once if caused by a Mercury system issue), and autopay authorization will automatically cancel after two consecutive failures in a series. You can prevent autopay cancellation by ensuring payers have sufficient funds, re-enrolling the payer, or requesting manual payment if the series fails twice.

View change record →
Medium May 29, 2026

The updated terms establish that when customers pay invoices you issue through Mercury Invoicing via ACH debit, Mercury will apply a hold period before crediting the funds to your account. The hold period is determined by Mercury in its sole discretion based on risk factors related to the transaction, payer, and payment history, and may range from 1 to 4 business days from the date the ACH debit is initiated. Mercury will display an estimated funds availability date for each incoming invoice payment in your Invoicing dashboard.

View change record →

Consumer impact (what this means for users)

Under this clause, merchants who receive invoice payments through Mercury Invoicing may experience funds availability holds of up to four business days, with the specific hold period determined by Mercury in its sole discretion based on undisclosed risk factors. Estimated availability dates displayed in the dashboard are not guaranteed and are subject to change.

Cross-platform context

See how other platforms handle Invoice Payment Holds at Mercury's Sole Discretion and similar clauses.

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▸ View Original Clause Language DOCUMENT RECORD
"
When a payer submits payment on an invoice you have issued through Mercury Invoicing via ACH debit, Mercury applies a risk-based funds availability period before crediting the payment to your Account. The applicable availability period is determined by Mercury in its sole discretion based on risk factors related to the transaction, payer, and payment history, and may be one (1), two (2), or four (4) business days from the date the ACH debit is initiated. Mercury will display an estimated funds availability date for each incoming Invoice Payment in your Invoicing dashboard. Mercury does not guarantee that funds will be available on any specific date, and estimated availability dates are subject to change based on returns, disputes, or other factors outside Mercury's control. Mercury reserves the right to modify its hold policies at any time.

Excerpt from Mercury's Terms of Service

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

1) REGULATORY LANDSCAPE: ACH payment processing and funds availability practices by non-bank financial service providers may engage FTC Act standards related to unfair or deceptive practices if availability timelines are materially misrepresented.

Insight

Unlock the full institutional analysis

Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.

Applicable agencies

  • Consumer Financial Protection Bureau (cfpb)
    Regulates consumer financial products and services. Can investigate companies for unfair, deceptive, or abusive financial practices including improper fees, billing errors, and data misuse.
    Who can file: Anyone who has used a consumer financial product or service in the US
    What you need: Account number or details, dates of transactions or events, description of the issue, and any supporting documents
    What to expect: The company must respond within 15 days. The CFPB forwards your complaint and may use it in enforcement actions. Individual compensation is possible in some cases.
    File a complaint →

Provision details

Document information
Document
Mercury Terms of Service
Entity
Mercury
Document last updated
May 5, 2026
Tracking information
First tracked
July 9, 2026
Last verified
July 9, 2026
Record ID
CA-P-014137
Document ID
CA-D-00529
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
3ac7ab54812d292da7660282e68a275955e77d625774ffe806d425e9b70bcc72
Analysis generated
July 9, 2026 04:51 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Mercury
Document: Mercury Terms of Service
Record ID: CA-P-014137
Captured: 2026-07-09 04:51:50 UTC
SHA-256: 3ac7ab54812d292d…
URL: https://conductatlas.com/platform/mercury/mercury-terms-of-service/provision/CA-P-014137/invoice-payment-holds-at-mercurys-sole-discretion/
Accessed: Sept. 26, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

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Frequently Asked Questions

What does Mercury's Invoice Payment Holds at Mercury's Sole Discretion clause do?

This provision establishes that merchants using Mercury Invoicing cannot rely on specific funds availability timelines, as hold periods are set by Mercury at sole discretion and estimated availability dates are explicitly not guaranteed. Mercury also reserves the right to modify hold policies at any time, creating ongoing operational uncertainty for merchants managing cash flow based on invoice payment schedules.

How does this clause affect you?

Under this clause, merchants who receive invoice payments through Mercury Invoicing may experience funds availability holds of up to four business days, with the specific hold period determined by Mercury in its sole discretion based on undisclosed risk factors. Estimated availability dates displayed in the dashboard are not guaranteed and are subject to change.

Is ConductAtlas affiliated with Mercury?

No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Mercury.