The Underwriting Checklist: Exactly What AI Companion Apps Need to Get Approved

How Adult Underwriting Actually Works

Underwriting for a AI companion app is a two-track review. Track one is financial: can this business process the volume it claims without collapsing into disputes and refunds? Track two is content compliance: does this operation meet the Visa VIRP and Mastercard §9.4.1 obligations the acquirer is personally liable for? Most declines happen on track two — not because the business is non-compliant, but because it can't *demonstrate* compliance in documents.

The underwriter's mindset: every unanswered question is risk, and risk is priced or declined. A file that anticipates the questions gets approved faster, priced better, and reserved lighter. Here's the complete file.

The Corporate & Financial Document Set

Every application needs: articles of incorporation/organization and EIN letter; government photo ID for all beneficial owners of 25%+; three months of business bank statements (personal accepted for new entities, but a business account strengthens the file); three to six months of prior processing statements if any exist — including from a processor that terminated you; a voided check or bank letter for settlement; and a completed application with honest volume, ticket (yours will center around $7.99–$29.99 monthly plans plus microtransaction message or image credits), and refund projections.

Volume honesty matters more than merchants expect: understating volume to look safer gets accounts frozen for "unexpected volume" later, while overstating triggers demands for financials. State what you actually expect, with a growth note.

The Content Compliance Evidence

This is where your vertical's file gets specific. Underwriters reviewing ai companion apps will look for: age gating at signup, content-tier separation (SFW vs NSFW), refund policy clarity, and moderation of user-directed generations. Package each item as a named document — banks approve what they can file, not what you describe on a call.

Additionally: apps with any NSFW capability are treated as adult merchants by the card networks regardless of how the app is marketed. If any element isn't built yet, build it before applying; "in progress" answers on content controls are the most common soft-decline trigger in this category.

Website Requirements Underwriters Screenshot

Before approval, someone at the bank walks your site with a checklist: age verification/18+ gate at entry; terms of service and privacy policy linked in the footer; a refund and cancellation policy that matches what checkout says; clear pricing and rebill disclosure at the point of sale; a billing descriptor disclosure ("charges appear as..."); working contact channels (email and phone); and 2257 compliance statement where applicable. They also test checkout — a broken or misleading checkout flow is an instant hold.

Two subtle ones: your site must be live (not a staging password page — provide credentials if pre-launch), and your marketing claims must match your application. A site advertising content categories your application didn't disclose reads as concealment.

The Seven Application Killers

(1) Concealing a prior termination or MATCH listing — banks check, and discovery converts a placeable file into a blacklisted one. (2) Miscoding the business as something mainstream. (3) Mismatched entity details across documents. (4) Personal accounts commingled with business flows. (5) Missing content compliance documentation. (6) Unverifiable ownership (nominee structures without disclosure). (7) Applying to one bank at a time and burning weeks per decline.

The fix for all seven is preparation plus placement strategy. Centurion pre-underwrites your file against the actual checklists of the acquirers we submit to, fixes gaps first, and runs parallel placements so a single bank's appetite doesn't set your timeline. Confidential file review: (561) 221-2273.

Frequently Asked Questions