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Rather than the merchant buying and reselling cheques (which creates a large revenue base for local tax), the merchant acts as a commission agent of the issuer. Under the agency model:
  • The merchant sells on behalf of the issuer, not on their own account
  • The merchant’s declared revenue = agent’s remuneration only (the markup they retain)
  • The face value pass-through is not the merchant’s revenue — it flows through to the issuer
  • This is the standard structure used by payment intermediaries, prepaid card distributors, and gift card networks globally

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What this means for the platform’s document model

The merchant does not receive a normal sales invoice from the issuer for each batch. Instead:
  1. Agency Agreement (contract, outside platform scope) — establishes the legal relationship
  2. Agent’s Report (агентский отчёт) — periodic document from merchant to issuer: “I sold X cheques, collected €Y, remitting €Z, keeping €W as my commission”
  3. Settlement Statement — from issuer confirming receipt and reconciling the period
  4. Rebate Notice — from issuer to merchant: “your rebate for this period is $X”