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Section 28 requires disputes between users and Wise to be resolved through individual arbitration rather than court proceedings, and waives participation in class action lawsuits and jury trials. Users may opt out of the arbitration requirement within 21 days of opening their account by following the procedure described in Section 28.2.9.
This analysis describes what Wise'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
This provision establishes that disputes must proceed through individual arbitration, which limits the procedural mechanisms available to users for resolving claims against Wise. The 21-day opt-out window is time-limited from account opening, and the agreement's disclosure of this deadline is a material factor in determining whether users have a practical opportunity to preserve access to court-based dispute resolution.
Interpretive note: Enforceability of the class action waiver may vary by jurisdiction, particularly in states such as California with heightened consumer protection statutes.
The explicit class action waiver language was removed in the current version, though arbitration remains; this change may allow for class actions depending on applicable law interpretation.
View full change record →The agreement requires disputes to be resolved through individual arbitration and waives class action participation unless the user opts out within 21 days of account opening. Users who do not opt out within that window will be subject to the arbitration clause for the duration of their account relationship with Wise.
How other platforms handle this
If, however, this Class Action Waiver is deemed invalid or unenforceable with respect to a particular Dispute...neither you nor Chegg will be entitled to arbitration of such Dispute.
except disputes relating to the enforcement or validity of your, your licensors', our, or our licensors' intellectual property rights
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"This Agreement contains a Dispute Resolution provision, at Section 28, which waives jury trials and class actions and allows either you or Wise to choose to have a dispute resolved in arbitration on an individual basis. You may opt out of arbitration within 21 days of opening your Account by following the instructions in Section 28.2.9.Excerpt from Wise's Terms of Use (Superseded URL)
1. REGULATORY LANDSCAPE: The arbitration clause engages the Federal Arbitration Act, which governs the enforceability of arbitration agreements in commercial contexts. The Consumer Financial Protection Bureau has previously issued rules on arbitration agreements in consumer financial contracts; the current regulatory posture of those rules should be evaluated. State consumer protection statutes in California and certain other states have examined the enforceability of class action waivers in financial services agreements, and applicability may vary by jurisdiction. 2. GOVERNANCE EXPOSURE: High. The class action waiver and jury trial waiver affect the procedural remedies available to consumers for disputes involving financial services, including potential regulatory violations, unauthorized transactions, or account errors. The enforceability of such waivers in consumer financial services contracts is subject to ongoing judicial and regulatory scrutiny, and the applicable law section of Section 28 should be reviewed to determine which state's law governs interpretation. 3. JURISDICTION FLAGS: California, New Jersey, and certain other states have challenged the enforceability of class action waivers in consumer contracts. The CFPB has authority over arbitration agreements in consumer financial products and services. Users in states with heightened consumer protection statutes may have additional arguments regarding enforceability that are not addressed in this agreement. 4. CONTRACT AND VENDOR IMPLICATIONS: The arbitration clause applies to disputes between the individual consumer and Wise US Inc.; its application to disputes involving API Partners or third-party service providers is not clearly addressed in the excerpted language and warrants review. The indemnification and liability limitation provisions elsewhere in the agreement interact with the arbitration clause in ways that procurement and compliance teams should map before onboarding Wise as a financial infrastructure provider. 5. COMPLIANCE CONSIDERATIONS: Legal teams should audit the account opening flow to confirm that the 21-day opt-out window and Section 28.2.9 instructions are disclosed at the point of account creation in a manner that satisfies applicable consent standards. The arbitration disclosure in the 'Important Things to Know' section should be evaluated against CFPB pre-dispute arbitration disclosure guidance. Periodic review of judicial decisions regarding the enforceability of class action waivers in the governing jurisdiction is advisable.
Regulatory citations, enforcement risk, and due diligence action items.
Coinbase's User Agreement includes a mandatory arbitration clause that most users may not have reviewed. Here is what the clause states and how the opt-out process works.
561 arbitration provisions across 197 platforms. ConductAtlas tracks how dispute resolution is being restructured across the internet.
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This provision establishes that disputes must proceed through individual arbitration, which limits the procedural mechanisms available to users for resolving claims against Wise. The 21-day opt-out window is time-limited from account opening, and the agreement's disclosure of this deadline is a material factor in determining whether users have a practical opportunity to preserve access to court-based dispute resolution.
The agreement requires disputes to be resolved through individual arbitration and waives class action participation unless the user opts out within 21 days of account opening. Users who do not opt out within that window will be subject to the arbitration clause for the duration of their account relationship with Wise.
ConductAtlas has identified this type of provision across 211 platforms. See the full comparison.
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