Learn · Rules, terms and compliance
How loyalty rules differ across jurisdictions
Loyalty rules change across borders on four recurring axes, namely whether points count as stored value that cannot lawfully expire, how marketing consent must be collected, whether unilateral change clauses survive unfair-terms review, and how unclaimed property law treats dormant balances. This page maps the axes. The specific rules in any jurisdiction need local counsel.
Loyalty rules differ across borders on four recurring axes, and the axes are stable even though the rules are not. Whether points may expire, how consent for data use must be captured, whether your right to change the terms survives review, and what happens to abandoned balances: each is answered differently in different places. This page maps the questions rather than the answers, because the answers need dated local verification this site does not hold.
## Expiry legality follows the stored-value question
Where points are characterised as stored value or prepaid consideration, expiry can be restricted or barred outright, and minimum validity or notice rules may apply. Where they are a revocable marketing licence, expiry is a contract term like any other. The same program can hold both characterisations in two markets at once, which means a single global expiry policy is a legal position, whether or not anyone adopted it deliberately.
## Consent regimes decide the enrolment flow
Opt-in regimes require an affirmative, unbundled choice before member data is used for marketing; opt-out regimes permit use until the member refuses. An enrolment flow built for an opt-out market, with a pre-ticked box and one bundled agreement, is invalid in an opt-in one, and consent captured invalidly poisons everything collected under it. This axis reaches past the legal team: it shapes the enrolment screens themselves and decides which members you may lawfully email.
## Unilateral change clauses are the least portable thing you have
The sentence programs lean on hardest, that terms may change at any time at the operator's discretion, is enforceable in some jurisdictions and void as an unfair term in others. A program whose economics depend on the freedom to devalue should establish, market by market, whether that freedom actually exists, and should do so before exercising it rather than after.
## Abandoned balances have a legal destination in some places
In the United States, unclaimed property law can claim dormant value for the state, subject to the characterisation questions the escheatment entry works through. Other jurisdictions have no equivalent and treat an abandoned balance as the program's windfall. The axis matters at the design stage because expiry windows and statutory dormancy periods interact, and the interaction differs by place.
## One term set or several, priced
A program operating in six markets faces a real trade. One global term set built to the strictest market means carrying the heaviest obligations everywhere: if one market requires 36 months of validity, balances that would have lapsed at 24 months in the other five stay live an extra year, and the liability tail lengthens in five markets to satisfy one. Six regional term sets avoid that carry and replace it with six documents to maintain, plus six legal reviews every time anything changes. Neither answer is wrong. The mistake is arriving at one by default and discovering later which trade was made.
What this page will not do is state any market's current rule. Statutes change, and a confident summary that has quietly aged is worse than none. Establish the four answers for each market you operate in with local counsel, and record the date you did it.