Compliance
The peptide compliance checklist: the 13-question boardable test
A peptide payments program is "boardable" only when the answer to all 13 questions is Yes. A single No is a stop. Here is the full pass/fail checklist.
Peptide Merchant Services — Compliance
The peptide compliance checklist: the 13-question boardable test
A peptide payments program is "boardable" only when the answer to all 13 questions is Yes. A single No is a stop. Here is the full pass/fail checklist.
Updated May 30, 2026 · 7 min read · https://peptidemerchantadvocates.com/resources/peptide-compliance-checklist
The short answer
The boardable test is a pass/fail checklist of 13 questions covering products, pathways, provider credentialing, state rules, anti-kickback controls, marketing claims, traceability, recall, and acquirer disclosure. There is no partial credit — every answer must be Yes, a single No is a freeze, and the test is run per merchant and re-run on every material change.
How does the boardable test work?
It is a one-page pass/fail gate that a founder, a sponsor bank, an acquirer, and a card-brand examiner can all read the same way. It is not a maturity score and there is no partial credit: a peptide payments program should not be boarded, funded, or scaled until every answer is Yes. A single No is a stop.
Run it per merchant, not once for the program — each merchant must independently pass all 13. Re-run it on every material change: a new SKU, supplier, state, payment rail, or sales channel re-opens the relevant questions.
The 13 questions
Every one must be answerable with a documented Yes:
- 1. Can you identify the exact active ingredient, salt form, route, and lawful pathway for every SKU?
- 2. Is every prohibited GLP-1 / cagrilintide / retatrutide-risk product removed?
- 3. Is the lawful seller the actual merchant of record for each transaction?
- 4. Is every provider credentialed beyond NPI (active license, scope, dispensing authority, no board discipline)?
- 5. Are state rules enforced at checkout (product × state × provider type)?
- 6. Are sales reps blocked from submitting orders under provider credentials?
- 7. Are sales-rep personal orders eliminated?
- 8. Are commissions and provider payments legally reviewed for anti-kickback / inducement risk?
- 9. Are all therapeutic / performance / disease claims stripped or substantiated?
- 10. Are lots traceable to clinic and patient where applicable?
- 11. Is there a functioning adverse-event and recall system (a mock recall locates 100% of affected lots)?
- 12. Is the acquirer fully aware of the catalog, claims, URLs, MCC, and risk controls?
- 13. Can the program produce a complete examiner-ready compliance binder within 48 hours?
How to use a No
A No is a freeze, not a footnote. If any answer is No, the affected SKU, provider, or channel does not transact until it is remediated to Yes. Each Yes should be backed by an artifact in your compliance binder — the SKU disposition register, credentialing records, state matrix, claims audit, recall SOP, and acquirer disclosure. The test is the index; the binder is the proof.
Key takeaways
- The boardable test is pass/fail — all 13 Yes, no partial credit.
- A single No freezes the affected SKU, provider, or channel until remediated.
- Run it per merchant, and re-run it on every material change.
- Back every Yes with an artifact in an examiner-ready compliance binder.
Frequently asked questions
What is the peptide "boardable" test?
A 13-question pass/fail checklist covering product pathways, GLP-1 prohibitions, merchant-of-record, provider credentialing, state-rule enforcement, anti-kickback controls, marketing claims, traceability, recall, and acquirer disclosure. Every answer must be Yes to board.
What happens if one answer is No?
A No is a stop. The affected SKU, provider, or channel does not transact until it is remediated to Yes — the same "no file, no SKU" discipline that governs the product whitelist.
Do I run the checklist once?
No. Run it per merchant, and re-run it on every material change — a new SKU, supplier, state, payment rail, or sales channel re-opens the relevant questions. A program that was compliant last quarter is not automatically compliant after a change.
What proves each "Yes"?
An artifact in your compliance binder: the SKU disposition register, credentialing records, state matrix, claims audit, recall SOP, and acquirer disclosure. The checklist is the index; the binder is the evidence.
Related compliance resources
More guidance on staying compliant and keeping payment processing in place.
- 10 things to know when selling BPC-157BPC-157 is one of the most searched peptides and one of the hardest to sell lawfully. Ten things every seller should understand about its regulatory status, marketing limits, and payment acceptance. 9 min read
- How to not get your peptide merchant account shut downA step-by-step operating playbook to keep a peptide merchant account boarded: what triggers a shutdown, the controls that prevent it, and the warning signs that mean you have days, not months. 10 min read
- How to legally run a peptide company in 2026A plain-English operating model for a defensible peptide business: lawful product pathways, the right entity, restricted marketing, and an examiner-ready payments file. 9 min read
- Is it legal to sell peptides? The four lawful pathwaysSelling peptides is legal only inside one of four FDA pathways. Here is what each one (FDA-approved, 503B, 503A, and research/IND) requires — and what falls outside the law. 8 min read
- 503A vs 503B for peptides: which compounding pathway fits?The difference between 503A and 503B decides whether you can sell office stock, who can be the seller, and what you can compound. Here is the practical breakdown for peptides. 7 min read
- Why "research use only" peptides can't be sold for human useSelling RUO or "not for human consumption" peptides into the physician-to-patient channel is one of the highest-risk models in the industry. Here is why — and what the FDA has said. 6 min read
This article is general educational information about regulatory frameworks (FDA, FTC, 503A/503B, DSCSA), not legal advice. Peptide compliance turns on product-specific and state-specific facts — review your model with qualified FDA, healthcare, and payments counsel before acting.
Keep reading
9 min read
How to legally run a peptide company in 2026
A plain-English operating model for a defensible peptide business: lawful product pathways, the right entity, restricted marketing, and an examiner-ready payments file.
8 min read
Is it legal to sell peptides? The four lawful pathways
Selling peptides is legal only inside one of four FDA pathways. Here is what each one (FDA-approved, 503B, 503A, and research/IND) requires — and what falls outside the law.
7 min read
503A vs 503B for peptides: which compounding pathway fits?
The difference between 503A and 503B decides whether you can sell office stock, who can be the seller, and what you can compound. Here is the practical breakdown for peptides.
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