7 Merchant of Record Examples: How Real Companies Use an MoR

Quick answer: The clearest merchant of record examples are ones you already use. The Apple App Store, Google Play, and Steam act as merchant of record for developers who sell through them. Amazon does it for its first-party sales. Paddle, FastSpring, and Comecero do it for software and SaaS companies. And any business selling through its own merchant account is its own merchant of record by default. In every case, the MoR is whoever is legally accountable for the payment, the tax on it, and the chargeback risk behind it.

The merchant of record concept is much easier to grasp through examples than definitions. The model is already everywhere in software and digital commerce, usually invisible to the customer and often only half-understood by the businesses relying on it.

This guide walks through seven real examples, explains what each arrangement actually covers, and shows how to work out who the merchant of record is on any given transaction. For the underlying concept, start with our guide to what a merchant of record is.

1. The Apple App Store

The textbook example. When you buy an app or subscription from the App Store, Apple is the merchant of record, not the developer who built the app.

Apple processes the payment, appears on the customer's card statement, collects and remits sales tax and VAT in every market it operates in, handles refunds, and absorbs the chargeback risk. The developer receives a payout after Apple's commission, typically 15% or 30% depending on the program.

Why it matters: an indie developer in one country can sell to customers in 175 markets without registering for tax anywhere, because Apple carries that burden. The trade-off is the commission rate and near-total loss of control over pricing presentation, checkout, and the customer relationship.

2. Google Play

Google Play works on the same principle for Android apps and in-app purchases. Google is the merchant of record, remits consumption taxes globally, manages refunds and disputes, and pays developers their share.

The example is worth noting alongside Apple because it shows the model isn't a quirk of one company. It's the standard structure for app distribution at scale, and for the same reason: managing tax registration and payment liability across every country individually would be impossible for most developers.

3. Steam and game distribution platforms

Steam acts as merchant of record for the game developers and publishers who sell through it, and console storefronts operate similarly.

The tax complexity here is significant. Games sell globally and instantly, digital-goods tax rules vary widely by jurisdiction, and refund policies are regulated differently across markets. Valve handles all of it as the MoR, then pays developers their revenue share.

Why it matters: for a game studio, this is often the difference between shipping globally on day one and spending months on tax registrations first.

4. Amazon's first-party sales

Amazon is a useful example because it demonstrates both sides of the model in one company.

For products sold and shipped by Amazon (the "Sold by Amazon" listings), Amazon is the merchant of record. It handles the payment, the tax, and the returns.

For third-party marketplace sellers, the picture is more nuanced. Amazon processes payments and, under marketplace facilitator laws in the US and equivalent rules elsewhere, now collects and remits sales tax on the seller's behalf in most jurisdictions. But the third-party seller typically remains the seller of record for the product itself, keeping warranty and product liability. This is exactly the split we cover in seller of record vs. merchant of record.

5. Paddle, FastSpring, and Lemon Squeezy

These are the dedicated third-party merchants of record for software and SaaS, and the closest examples to what most software companies actually need.

The mechanics: you sell your product to the platform, the platform resells it to your customer. Because it is the legal seller, it collects and remits VAT and sales tax worldwide, absorbs chargebacks, maintains PCI compliance, and handles billing support. You keep your own branding, your own site, and your own customer relationship. The MoR sits underneath the transaction rather than in front of it.

Each targets a different segment. Paddle serves scaling SaaS with an API-first platform, FastSpring serves traditional software sellers with two decades of history, and Lemon Squeezy serves indie founders with a simpler on-ramp. We compare them directly in Paddle vs. FastSpring and Paddle vs. Lemon Squeezy.

Why it matters: unlike the App Store model, you don't surrender the customer relationship or the storefront. You transfer the liability while keeping the business.

6. Comecero

Comecero is a merchant of record built specifically for SaaS, AI, and high-ticket digital sellers.

The MoR fundamentals are the same as any full-service provider: legal seller on each transaction, global tax and VAT remittance, chargeback and fraud liability, PCI compliance. What differs is what sits on top. The platform is built around usage-based and hybrid billing for metered products, acceptance on large transactions for high-ticket sellers, and active recovery of revenue that most platforms leak through failed payments, weak dunning, and unoptimized checkout.

Why it matters: it's an example of the MoR model applied to billing patterns the older platforms weren't designed for, particularly usage-based billing for AI companies and high-ticket transactions.

7. Your own business (the default example)

The example everyone forgets: if you sell through your own merchant account with a payment processor, gateway, or payfac, you are the merchant of record.

This isn't a choice you make. It's the default state whenever nobody else takes the role. Being your own MoR means you:

• Register for sales tax, VAT, and GST wherever you cross a threshold, then file and remit in each one
• Absorb chargebacks and fraud losses directly
• Maintain PCI compliance yourself
• Hold the merchant account relationships and answer to acquirers
• Handle billing support and refund mechanics

Plenty of businesses run this way successfully, particularly those selling in a single market with straightforward tax rules. It also preserves the most margin per transaction, since you're not paying a provider for risk transfer. The overhead scales painfully once you sell across borders, which is the point at which most software companies switch.

Worth stressing: using Stripe, PayPal, or Square does not change this. Those are payment processors or payment facilitators, not merchants of record, so you remain the MoR and keep the tax and compliance liability. (See Merchant of Record vs. Payment Service Provider and Merchant of Record vs. Payment Gateway.)

Merchant of record examples compared

Example	Who is the MoR	Who sells	Typical use case
Apple App Store	Apple	Apple (resells the app)	Mobile apps and in-app purchases
Google Play	Google	Google	Android apps and subscriptions
Steam	Valve	Valve	PC games and DLC
Amazon (first-party)	Amazon	Amazon	Retail goods sold by Amazon
Paddle / FastSpring / Lemon Squeezy	The platform	The platform (resells your product)	Software and SaaS, own storefront
Comecero	Comecero	Comecero (resells your product)	SaaS, AI, usage-based, high-ticket
Your own merchant account	You	You	Single-market or margin-maximizing sellers

How to tell who the merchant of record is

Three reliable checks, useful both for your own setup and for understanding a competitor's:

Look at the card statement descriptor. The name that appears on the customer's bank statement is the merchant of record, or a descriptor it controls. If your own company name appears there and you haven't contracted an MoR, you are the MoR.

Read the receipt and the checkout terms. A third-party MoR will normally identify itself on the invoice, often with wording like "sold by" or a reseller notice, along with its own tax identification numbers.

Check who remits the tax. This is the decisive test. If nobody is filing VAT returns on your behalf in the markets you sell into, no MoR is in place, whatever your payment provider's marketing says. Ask the provider directly: "who is contractually liable for remitting VAT in the EU on our sales?" The answer tells you everything.

The bottom line

The merchant of record model isn't exotic. It's the structure behind the App Store, Google Play, Steam, and most of the software you buy online. In every example the pattern is identical: one entity takes legal accountability for the payment, the tax on it, and the risk behind it, so the business that built the product doesn't have to.

The only real question is which entity that is for your business. If no third party has taken the role, it's you, along with every tax registration and chargeback that comes with it.

If you'd rather hand that burden to a provider built for your billing model, talk to the team at Comecero. We act as merchant of record for SaaS, AI, and high-ticket digital sellers, covering global tax, chargebacks, and compliance in one relationship, with revenue recovery built in.