Breaking changes

Adds specific descriptions for risk requirements during legal, PEP, and sanctions review Breaking changes

What’s new

Adds two new requirements, resolution paths, and a new error code for risk requirements related to legal holds, PEP reviews, and sanctions reviews. These were previously categorized as other_supportability_inquiry or other_compliance_inquiry requirements. Risk verification requirements follow the <id>.<requirement_description>.<resolution_path> format.

This update adds the:

• external _ hold error code to the requirements. errors array in the Accounts API .
• notice resolution path to risk verification requirements .

This update also adds the following new descriptions to risk verification requirements:

• legal _ hold : We must hold funds for legal reasons. Fulfilling the requirement can involve remitting funds to a third party.
• pep _ review : We need to verify that the business isn’t involved with a person of interest or a politically exposed person.
• sanctions _ review : We need to verify that the business isn’t involved with a sanctioned person or jurisdiction.

Requirements with a description of sanctions_review or pep_review show up in pending_verification to indicate that the requirement is pending review by Stripe and doesn’t require any user action to resolve.

Why is this a breaking change?

This change will break existing integrations that aren’t updated to explicitly handle these new requirements. Sanctions, PEP review, and legal hold requirements were previously represented by the less-specific other_supportability_inquiry requirement description.

The following example shows a truncated response from the v1/accounts API for an account with payouts disabled due to a legal hold

{
 "id": "acct_123",
 // ...
 "requirements": {
 "alternatives": [],
 "current_deadline": null,
 "currently_due": [
 "interv_def789.legal_hold.notice"
 ],
 "disabled_reason": "requirements.past_due",
 "errors": [{
 "requirement": "interv_def456.legal_hold.notice",
 "code": "external_request",
 "reason": "There is an active levy on this account. Ask the account to have the government agency, Llama Revenue Services, send a signed release to llg-notices@stripe.com."
 }],
 "eventually_due": [
 "interv_def789.legal_hold.notice"
 ],
 "past_due": [
 "interv_def789.legal_hold.notice"
 ],
 "pending_verification": []
 },
 "payouts_enabled": false,
 // ...
}

This example shows a truncated response from the Accounts v1 API for an account that has payouts disabled due to both a pending sanctions and a pending PEP review

{
 "id": "acct_456",
 // ...
 "requirements": {
 "alternatives": [],
 "current_deadline": null,
 "currently_due": [],
 "disabled_reason": "requirements.pending_verification",
 "errors": [],
 "eventually_due": [],
 "past_due": [],
 "pending_verification": [
 "interv_def123.sanctions_review.support",
 "interv_def456.pep_review.support",
 ]
 },
 "payouts_enabled": false,
 // ...
}

Impact

You will gain a better understanding of capability limitations caused by sanctions reviews, PEP reviews, and legal holds and whether any action is required from you to resolve the requirement.

Changes

Upgrade

1. View your current API version in Workbench.
2. If you use an SDK, upgrade to the corresponding SDK version for this API version.

• If you don’t use an SDK, update your API requests to include Stripe-Version: 2025-09-30. clover

3. Upgrade the API version used for webhook endpoints .
4. Test your integration against the new version.
5. If you use Connect, test your Connect integration .
6. In Workbench, perform the upgrade . You can roll back the version for 72 hours.

Learn more about Stripe API upgrades.

Related changes

• Adds a new error code for business type validations
• Adds account balance and payout settings with the Balance Settings API