Final guidelines for the formatting and use of Quick Response (QR) Codes for electronic billing via mobile devices have been issued by NACHA – The Electronic Payments Association’s Council for Electronic Billing and Payment (CEBP). The guidelines propose a standard format and protocol for QR Codes, which are used by consumers to view billing information, pay bills, sign up for electronic billing with direct billers, or to bank online with financial institutions or bill payment services providers.

A QR Code is a matrix barcode label that can be quickly read by a mobile phone. Such codes often appear in magazine advertisements and on billboards. An example can be found below.


The “Quick Response (QR) Encoding for Consumer Bill Pay Guidelines” establish a single, voluntary standard for QR Code use in billing. With wide adoption of this standard, customer online payment experiences will be more consistent. The new guidelines present recommendations and options regarding QR Code size, the use of URL shorteners, the types of data to be included in the QR Code, and a single standard for the ordering and formatting of such data.

The guidelines allow for a single QR Code to be used for multiple functions. For example, a QR Code on a billing statement could be initially scanned by a consumer so that the consumer is directed to the website of the biller or online banking or bill payment service provider. After the customer’s identity is authenticated, the customer could then scan the QR Code again, view his or her billing statement directly on his or her mobile device, and access the bill payment function.

The CEBP said its next step is to organize a pilot program with various stakeholders to demonstrate the usefulness of the guidelines and to encourage industry-wide adoption of them. When implemented fully, the guidelines could prove to be an important and workable part of making managing and paying bills easier in the mobile channel than ever before.

Information about obtaining a copy of the guidelines is available in NACHA's press release.

Ballard Spahr attorneys regularly advise financial institutions and other companies on developing financial services in the mobile channel to ensure compliance with consumer financial services laws, as well as related data security and privacy laws. The firm's Consumer Financial Services Group is nationally recognized for its guidance in structuring and documenting new consumer financial services products as well as its experience with the full range of federal and state consumer credit laws. 

Members of the Consumer Financial Services Group who are also part of the Privacy and Data Security Group focus on financial privacy by design—evaluating new products and services and communications channels to ensure that financial institutions are meeting their privacy and data security obligations. 

For more information, please contact Glen P. Trudel at 302.252.4464 or

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