Provision record
PayPal · PayPal User Agreement · View original document ↗

Fund Holds, Reserves, and 180-Day Hold Authority

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Document Record

What it is

Generated by a model from the captured document; not read by a person

PayPal may hold user account balances for up to 180 days in connection with restricted activities, risk determinations, or Acceptable Use Policy violations, with the possibility of longer holds under court orders or regulatory requirements. Separate risk-based holds on individual payments may last up to 21 days, and dispute-related holds may last up to 180 days.

ⓘ

This analysis describes what PayPal'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)

Generated by a model from the captured document; not read by a person

This provision authorizes PayPal to restrict access to account balances for extended periods based on its sole discretion risk assessments, which may affect a user's or business's cash flow and operational continuity. The agreement discloses that decisions may be based on confidential criteria that PayPal is not obligated to share with users.

Recent Activity

This document changed recently

High Sep 15, 2026

The updated terms establish mandatory arbitration for most disputes, including those arising before or after the agreement, and add explicit class action and jury trial waivers. Under the revised language, disputes must proceed through individual arbitration rather than court litigation, and users waive the right to participate in class actions. The agreement requires a 60-day informal resolution attempt before arbitration begins and imposes detailed Notice of Dispute requirements, including original handwritten signatures and identity verification. You can opt out of arbitration by sending a written notice postmarked within 30 days of first accepting the agreement.

View change record →

If You Do Nothing

⚠ Funds subject to a hold will remain unavailable for withdrawal until the hold conditions are resolved or the hold period expires.

⚠ If a negative balance results from a reversal during a hold period, the user is required to immediately add funds to resolve it.

Cross-platform context

See how other platforms handle Fund Holds, Reserves, and 180-Day Hold Authority and similar clauses.

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▸ View Original Clause Language DOCUMENT RECORD
"
Holding the balance in your Balance Account, the balance in your business account, or any money waiting to be claimed through your personal account if you do not have a Balance Account linked to your personal account, for up to 180 days if reasonably needed to protect against the risk of liability or if you have violated our Acceptable Use Policy. The hold may remain in place longer than 180 days according to Court Orders, Regulatory Requirements, or Other Legal Processes.

Excerpt from PayPal's User Agreement

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

1) REGULATORY LANDSCAPE: Fund hold and reserve practices engage applicable state money transmitter laws, which in many states impose requirements on the treatment of user funds and may require disclosure of hold policies.

Insight

Unlock the full institutional analysis

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

Applicable agencies

  • CFPB
    The CFPB has supervisory authority over PayPal as a nonbank payment service provider and may be relevant to disputes regarding fund holds and consumer access to account balances.
    File a complaint →

Provision details

Document information
Document
PayPal User Agreement
Entity
PayPal
Date stated by the document
Sept. 14, 2026
As printed in PayPal’s text (version CA-V-006945), not a ConductAtlas date.
Tracking information
First captured by ConductAtlas
March 6, 2026
Text quoted from version
CA-V-006945, captured Sept. 15, 2026
Document ID
CA-D-000044
Evidence Provenance
Source URL
Wayback Machine
Archived bytes SHA-256 (version CA-V-006945)
5e7c2cacffde4abbe731dc29303783a6c042ff6fd73b3e44e331dd7fcf8b14d2
Analysis generated
September 16, 2026 02:01 UTC
Methodology
Evidence
Excerpt not yet checked against a stored version
Citation Record
Entity: PayPal
Document: PayPal User Agreement
Version: CA-V-006945
Captured: 2026-09-15 00:10:50 UTC
SHA-256: 5e7c2cacffde4abb…
URL: https://conductatlas.com/platform/paypal/paypal-user-agreement/fund-holds-reserves-and-180-day-hold-authority/
Accessed: Oct. 22, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.

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Frequently Asked Questions

What does PayPal's Fund Holds, Reserves, and 180-Day Hold Authority clause do?

This provision authorizes PayPal to restrict access to account balances for extended periods based on its sole discretion risk assessments, which may affect a user's or business's cash flow and operational continuity. The agreement discloses that decisions may be based on confidential criteria that PayPal is not obligated to share with users.

Is ConductAtlas affiliated with PayPal?

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