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KYC Gap: How Pre-paid Cards Impact 2026 Clinical Trial Compliance

Randa Bennett |

With the UK Clinical Trial Regulations 2026 coming into place in April, Sponsors are reviewing their data workflows to ensure compliance before the April deadline.

For most Sponsors and CROs, participant reimbursement feels like a simple admin box to tick. You hand out a pre-paid card; the patient gets their travel money and stipend. But there is a hidden "KYC Gap" in this process that is creating a massive UK GDPR and data liability risk.

The KYC Trap: Why Pre-paid Cards are a Liability in Clinical Trials When you use a legacy pre-paid card, you aren't just sending money; you are forcing your participants into a financial agreement that requires them to hand over masses of personal data, here are the risks:

1. The Data Handover: 

Because these cards are financial products, participants must provide sensitive "Know Your Customer" (KYC) data, like their full name, date of birth, and even a photo of their passport, just to activate the card to get reimbursed. 


2. The "Jurisdiction" Problem 

Most major pre-paid card providers for Clinical Trials are US-based. Under the US CLOUD Act, the US government can legally demand access to data held by these companies, even if the data is hosted in the UK and of UK citizens.

3. The Anonymity Risk:  

This is where the liability becomes invisible. Because legacy pre-paid cards require full KYC (passports and IDs), they create a permanent link between a participant’s identity and the trial. Under the US CLOUD Act, US authorities can request this data, and often, they can legally prevent the card company from even notifying you. You could have a major compromise of participant anonymity and never even know it happened

By using these cards, you may be unintentionally "exporting" participant identities outside of UK jurisdiction. This creates unnecessary complexity for your trial integrity and makes it harder to stay aligned with the ICO’s (Information Commissioner’s Office) latest guidance on data sovereignty.

The Catch: It’s Your Responsibility to Manage, the ICO is clear: you cannot "outsource" your legal accountability. If a payment process leads to a privacy risk or inadvertently compromises participant anonymity, the regulator won't hold the card issuer responsible. They will look to you, the Sponsor and Data Controller, to ensure the data journey was handled correctly - a key priority for the 2026 UK Clinical Trial Regulation updates.

Don't let a minor reimbursement lead to a major privacy breach. 

The solution is simple: A payment process that captures minimal data and keeps it entirely within UK jurisdiction

vHelp facilitates secure direct-to-bank transfers in <24h.

  • Zero KYC Burden: We don’t ask participants for IDs, we capture minimal data to process the payment

  • UK Sovereignty: All data stays within UK jurisdiction.

  • Participant-Centric: It’s user friendly, fast and inclusive

Real-World Success: The NeuroClin Story

We don’t just talk about solving the "KYC Gap”, we’ve done it. One of the UK’s leading clinical research sites, NeuroClin, faced the exact administrative and data burdens we’ve described. By moving away from legacy pre-paid cards and adopting vHelp, they transformed their participant experience and streamlined their compliance.

Read the Full Case Study: How vHelp Transformed NeuroClin’s Participant Expenses

Keep your data, your participants, and your reputation securely in the UK.

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