Payment Gateway Due Diligence Checklist for CTOs
CTO payment gateway due diligence covers: 1) Regulatory — is the gateway licensed by CBN/CBK/BoG/RBZ in each country? 2) Security — PCI-DSS compliance level, fraud tools, chargeback dispute support. 3) API quality — working sandbox, error code documentation, webhook reliability, test card suite. 4) Settlement — timing, net vs gross, what's deducted, FX policy for multi-currency. 5) Pricing — all fees disclosed upfront: transaction %, flat fee, refund fee, chargeback fee, monthly minimum. 6) Data — where is transaction data stored, can you export it, what happens if you leave. 7) Support — response time commitment, dedicated account manager at what volume threshold.
Due Diligence Checklist
| Category | Check | What to Verify |
|---|---|---|
| Regulatory | CBN licence (Nigeria) | Verify at CBN website or official gazette — not just gateway's claim |
| Regulatory | CBK PSP licence (Kenya) | Check CBK's Payment Service Provider list |
| Regulatory | BoG EMI/PSP licence (Ghana) | Check Bank of Ghana payment systems registry |
| Security | PCI-DSS compliance | Ask for Attestation of Compliance (AOC) document |
| Security | HMAC webhook signature | Does the gateway sign webhooks? What algorithm? |
| Security | Fraud screening | Is there built-in fraud scoring? What are the thresholds? |
| API | Sandbox environment | Test yourself — does it work for your use case? |
| API | Error documentation | Is every error code documented with expected response? |
| API | Webhook reliability | Check developer community (Twitter/X, forums) for reports |
| Settlement | Settlement timing | T+1? T+3? When does money arrive in your account? |
| Settlement | Net vs gross | Is fee deducted from each transaction or from settlement batch? |
| Pricing | Full fee schedule | Transaction %, flat fee, refund fee, chargeback fee, FX markup, monthly minimum |
| Data | Data export | Can you export all transaction data in CSV/JSON? What happens at account closure? |
| Data | Data residency | Where are customer and transaction records stored? Relevant for NDPA/DPA compliance. |
| Support | Response time | What is the SLA for technical support tickets? For account holds/freezes? |
| Support | Dispute resolution | How are chargebacks handled? What evidence is required? |
Learn More
See payment gateway SLAs and what they actually cover for interpreting the uptime commitments you will find in contracts.
Key Takeaways
- ✓Verify regulatory licence in each country before going live — an unlicensed gateway can be shut down without warning.
- ✓PCI-DSS compliance is not optional — confirm the gateway's SAQ level and what it covers.
- ✓Request the full pricing schedule including refund fees, chargeback fees, and FX markup — not just the headline rate.
- ✓Test the sandbox environment yourself before selecting — broken sandboxes indicate poor engineering culture.
- ✓Ask what happens to your data if you close the account — exportability matters for migration and compliance.
Frequently Asked Questions
- What is PCI-DSS and why does it matter for my gateway selection?
- PCI-DSS (Payment Card Industry Data Security Standard) is the security standard that governs how card data is handled. A gateway that is PCI-DSS compliant has had its systems audited against this standard. This matters because: if you use a non-compliant gateway and a breach occurs, you may be liable even if the breach happened on the gateway's side. Paystack is PCI-DSS Level 1 compliant — the highest level. Always ask for the Attestation of Compliance (AOC) document.
- What happens to my data if the payment gateway shuts down?
- This is a key due diligence question. Ask explicitly: "If we close our account or you cease operations, in what format and for how long can we export our transaction data?" Transaction history (for accounting, compliance, tax purposes) must be preserved for 5-7 years depending on jurisdiction. A gateway that cannot guarantee data export is a risk. Paystack allows transaction data export via CSV from the dashboard and via API.
- How common are gateway account freezes, and what causes them?
- Account holds and freezes do happen — typically triggered by unusual transaction patterns, chargeback rates exceeding thresholds, compliance flags, or regulatory action against the gateway itself. Ask the gateway: "What triggers an account hold? What is the notification process? What is the resolution timeline?" Paystack generally sends email notifications and has a support process for holds, but resolution speed varies. Having an emergency backup gateway is prudent for businesses where payment downtime has severe revenue impact.
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