Pelarys Intelligence · PYPL · PayPal Holdings, Inc.
PayPal disclosed a new FTC investigation into its fees and purchase protection — in its 10-Q, not its earnings release
PayPal's quarterly report for the period ended September 30, 2026 discloses that in September 2026 it received a civil investigative demand from the Federal Trade Commission. The FTC is investigating whether PayPal engaged in deceptive, unfair or otherwise unlawful practices in how it advertises, markets, sells, issues or manages fees and purchase protection for financial products and services. PayPal says it is cooperating. The filing does not disclose an accrual, a loss estimate or any outcome for this matter.
What changed
The disclosed terms
- New FTC civil investigative demand received
- September 2026
- Subject
- Advertising, marketing, sale, issuance or management of fees and purchase protection for financial products and services
- What the demands ask for
- Documents, answers to written questions and other information
- Open FTC demands PayPal now lists
- Three: February 2022, August 2025 and September 2026
- Accrual or loss estimate for this matter
- Not disclosed
- Which products, and any outcome
- Not disclosed
The evidence
Read it in the filing
PayPal Holdings, Inc. · Form 10-Q · filed October 27, 2026
Accession 0001633917-26-000088 · Part I, Item 1 — Note 13, Commitments and Contingencies (Regulatory proceedings)
“In September 2026, we received a CID from the FTC investigating whether PayPal engaged in deceptive, unfair, or otherwise unlawful practices in connection with the advertising, marketing, sale, issuance, or management of fees and purchase protection in connection with financial products and services.”
“The CIDs request the production of documents and answers to written questions, as well as other information.”Read PYPL's filings on SEC EDGAR
Every figure above is a disclosed term and every quotation is verbatim. Verified against the primary source on 2026-10-28.
Why it matters
What a screen missed, and what it costs
The demand appears only in the regulatory-proceedings section of the notes to PayPal's financial statements. PayPal's third-quarter earnings release does not mention it, and the company's previous 10-Q, for the quarter ended June 30, 2026, did not list it.
The earlier FTC demands PayPal discloses concern merchants on its platform: commercial customers that submit charges for other sellers, and its onboarding and due diligence. This one concerns PayPal's own practices on fees and purchase protection for financial products and services. A civil investigative demand is a request for documents and information; the filing does not say the FTC has made any finding, and PayPal discloses no accrual or loss estimate for it.
What Pelarys remembered
The pattern behind it
PayPal's FTC disclosures have been cumulative. February 2022 concerned commercial customers that submit charges on behalf of other merchants; August 2025 concerned whether its onboarding and due-diligence practices facilitated merchant schemes. The September 2026 demand is the third, and the first of the three directed at fees and purchase protection.
What to look for next
Still open
- Whether PayPal's next 10-K still lists the September 2026 demand, and in what form
- Whether PayPal discloses an accrual or a range of reasonably possible loss for it
- Any change in how PayPal describes fees or purchase protection for the affected products
- Any FTC complaint, consent order or closing letter related to the demand
This is one finding. Follow the company for the next one.
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