Credit Card Merchant Category Code Requirements

Current Law

New York General Business Law Section 529-a requires use of the merchant category code established by the International Organization for Standardization for firearms and ammunition businesses. Senate Bill S8479A became Chapter 430 of the Laws of 2024 on October 9, 2024. Senate Bill S745 became Chapter 116 of the Laws of 2025 on April 3, 2025, and removed dealers of ammunition as a separate covered category before the assignment requirement took effect.^[1][2][3]

Which Dealers Are Covered

For this law, a dealer of firearms is a New York gunsmith or firearms dealer licensed under Penal Law Section 400.00 whose highest sales value is, or is expected to be, from the combined New York sale of firearms, firearm accessories, or ammunition. The business states that sales profile to its merchant acquirer in the ordinary course of business.^[1]

Required Assignment

• Payment card networks: By November 1, 2024, each network had to make the firearms and ammunition merchant category code available to merchant acquirers that serve covered firearms dealers.
• Merchant acquirers: Beginning May 1, 2025, each merchant acquirer must assign that code to each covered firearms dealer in New York.

Section 529-a places these duties on payment card networks and merchant acquirers. It does not direct an individual dealer to assign its own code.^[1]

What the Code Identifies

The merchant category code classifies the merchant. Section 529-a does not create an item-level purchase record, a purchaser registry, or a separate transaction-reporting requirement. The statute requires the category code to be available and assigned to covered dealers.^[1]

Enforcement

When the Attorney General identifies a violation, the office must give written notice identifying the provisions violated. The Attorney General may not bring an action if the recipient cures the violation within 30 days and supplies the required written confirmation, supporting documentation, and policy changes. If the violation is not cured, the Attorney General may seek an injunction and restitution. A court may impose a civil penalty of up to $10,000 for each violation, along with reasonable attorney fees and investigation costs.^[1]