Pay3 scores 6.3 out of 10: a collateral-based Visa from Hong Kong with a published fee floor and an unpublished country list

Updated October 2026

Licensed

Available in US

Fast payouts

18+ Only

Pay3 is a payment card you back with crypto. You put collateral in, the collateral sets your spending limit, and you spend against it through a Visa — virtual in the app, physical in the post, and tokenised into Apple Pay and Google Pay. The idea is simple and, for the audience it targets, genuinely useful: people who want a normal-looking card to spend from a crypto balance, without a bank in their own country going along with it.

My overall mark is 6.3 / 10. That is not a dismissal. It is a card that does the basics competently and is unusually transparent about the two things that usually get hidden — that it is not a bank, and that it holds no insurance on your money. It is also a card where a surprising amount is simply not published: no country list, no coin list, no card currency, no withdrawal fees, no ATM allowance. You are asked to attest things about yourself rather than shown a table of what applies where.

Who it suits: anyone who already holds stablecoins or crypto, can clear an identity check in the app, lives outside the restricted set, and wants a Visa for everyday spending rather than an exchange-branded card. Who it does not suit: anyone who wants the card to hold their money, anyone who needs a wide ATM network, anyone who buys things they cannot easily dispute, and anyone who needs to know in advance exactly which country list they are on.

The conditions described here are current as of October 28, 2026.

The 8 out of 10 for everyday use is where the card earns its best mark, and it is worth saying why before I get into the problems. Virtual card immediately, physical card in “3–5 business days”, Apple Pay and Google Pay, a spent-from-per-transaction floor rather than a subscription. That is a complete everyday toolkit for someone who lives their life on their phone. The 5 out of 10 for cost is the counterweight: a 3% ceiling on three separate currency-related fees is not a rounding error, and if you spend abroad regularly it will matter more to you than the $5 issuance ever does.

Will they give you the card?

Yes, most likely, if you are outside what Pay3 calls “Restricted Locations” — and no, you cannot check whether you are, because the list is not published.

Here is the rule as the card states it. Pay3 is open to users outside “Restricted Locations”, which it defines as countries under trade sanctions, export controls, or crypto and fintech prohibitions. Users who are citizens or residents of a Restricted Location are excluded. The list itself is not published, and the card says it may change without notice. On top of that, the card terms require users to attest that they are not a US citizen and not OFAC-blocked.

That last part catches people out. This is not just “we don’t serve the United States”. A US citizen living in, say, Portugal, is asked to attest they are not a US citizen. If you are one, the answer at the attestation step is not a workaround question — it is a straight declaration, and the truthful answer ends the application.

The country list being unpublished is the single most awkward thing about eligibility. You can read the rule and still not know whether your country is in it. In practice the way this resolves is: you try, and either the application proceeds or it does not. I would rather you knew that going in than discovered it after uploading a document.

Two more things that belong in this section rather than buried later. The age floor is 18, or the legal age where you are. And the standard anti-money-laundering backdrop applies here as it does to any regulated product: identity verification is a legal requirement for businesses in this space, not a preference, and it is screened against sanctions lists that are applied to citizenship and country of birth, not just to your address. That is why a card can accept residents of a country and still refuse citizens of another.

How to get it

Three steps, one of which may take longer than you expect: verify your identity in the app, apply for a card, fund it.

The identity check runs through Sumsub, inside the app, and happens once. That single verification is reused across the card, the account and swaps, so you are not re-uploaded for each product. Depending on the partner and your region, an extra document — typically proof of address — may be requested on top of the identity document.

The application itself is separate from the check. You verify, you apply, you fund. The levels of verification are not published, and neither is the processing time or the list of rejection reasons. A failed identity check may lead to suspension of the account, which is worth weighing before you upload anything: there is no published appeal process and no stated timescale.

The card itself comes in virtual and physical forms, and both Apple Pay and Google Pay cards are offered. The card terms say it is issued “under license from Visa”. One small detail that turns out to matter later: the card’s currency is not stated outright anywhere. You can infer a US-dollar basis from the fact that there is a separate fee for non-USD transactions, but that is an inference, not a published specification.

Delivery: the virtual card is ready right after you apply. The physical card takes “3–5 business days”. Countries shipped to, shipping cost and replacement cost are not stated. If you lose the card or it is stolen, you can replace it through the account and may be issued a new number.

The two-tier question comes up because the card documentation names a Pay3 Credit Card and a Pay3 Black. The differences between the tiers are not published on the pages I read, and there is no third-party source I would trust to fill that in.

Fees: what it really costs

The headline numbers look reasonable. The tail of them does not. Pay3 publishes a floor for nearly every charge and a ceiling for the currency-related ones, which means your actual bill sits somewhere in a range the card does not narrow down.

Fees vary by card type, currency and location — the card says so, without saying by how much in each case.

Let me take three ordinary payments and run them against that table, because the abstract figures hide the structure.

A $40 grocery shop in your own country, on the virtual card. This is the cheap case. You are spending a dollar-denominated balance in a dollar context, so the FX and cross-border lines do not bite. What you pay is the per-transaction fee starting from $0.15. On $40 that is the best-value payment the card will ever process for you.

A €28 dinner in a eurozone city, paid on the physical card. Now the currency lines stack, and the card does not tell you how they stack. If the conversion rate of “from 1.15%” applies, the euro-to-dollar conversion costs you a share of it. If the transaction is treated as non-USD, the foreign exchange fee can reach 3%. If it is treated as cross-border, the cross-border fee can reach 3%. And a foreign transaction fee of up to 3% exists as a separate line again. I cannot tell you from the published terms whether these are alternative labels for the same charge or additive layers. That ambiguity is itself the finding: budget the top of the range, not the floor.

A $12 subscription paid from a phone, on the tokenised card. Tokenisation removes your card number from the transaction — the phone substitutes a device-specific number and a one-time code per payment — but it does not change the fee schedule. Apple Pay and Google Pay are payment channels, not discount channels. The same per-transaction floor applies, and the merchant’s own decline rules still do.

The limit structure deserves its own paragraph because it is unusual and easy to misread. There are no fixed limits. Your spending limit equals the US dollar market value of your posted collateral. “Posted” is doing real work: collateral that is in flight, or not yet credited, does not count. And Pay3 may change your limit with or without notice, including down to zero. A limit that can move without warning is not a bug you can complain your way out of; it means your card can stop working at the worst possible moment, and the collateral is still yours.

On ATMs, the card terms say cash advances and balance transfers are not available. Platform terms mention that physical cards “may support” ATM cash withdrawals, subject to partner policies. Fee and allowance are not stated. “May support” is not a promise, and I would plan on it never happening.

Top up

Top-up is the part of the card that is cleanest on paper. You add stablecoins, or you add fiat into a multi-currency account. Adding funds is free, and the top-up fee is 0%.

Two structural points sit underneath that. First, the card is collateral-based: the collateral sets the limit, so topping up is not a top-up in the ordinary sense of adding spending money, it is more like moving your own holdings across. Second, the multi-currency account shows cash, stablecoin and card balances together, which is convenient precisely because it hides which of them is funding which purchase.

What is not stated is the part that would actually bite. The specific coins and networks are not listed on the site. The minimum top-up is not stated. Who pays the on-chain network fee is not stated — and it matters, because on some networks the fee can only be paid in that network’s own token. If you send USDT over a network you hold no gas token for, the transfer fails; if you send on a network the provider does not support, funds can be lost or need manual recovery with no guarantee. This is where I would want to see the coin and network list in writing before sending anything.

Withdrawals: “Withdrawals are available”, and the fees are not stated. The terms describe no withdrawal process at all. They do note that extra verification may be needed to retrieve residual balances after termination. That sentence is small and it tells you a lot — it implies that getting money back out is not automatic, and that in some endings it needs paperwork.

One unofficial note, flagged as such: a third-party review site reported in 2026 that the Black tier carries no spend cashback, only non-transferable referral points redeemable against issuance. I have not seen this on Pay3’s own pages, and I would not plan a rewards strategy around it.

Paying with it every day

Here is the card at its best, and it is a genuinely good everyday setup: a virtual Visa you get immediately, a physical one in a few days, and both available in Apple Pay and Google Pay. Spend from a balance, not a credit line you have to service.

Wallet support covers Apple Pay and Google Pay. When you add the card to your phone, the card number is replaced by a device-specific number held in the phone’s secure hardware, never on the vendor’s servers, and each payment carries a fresh one-time code. The issuer can still restrict a tokenised number — blocking it on magnetic stripe, on phone, or on websites — so the token is not a bypass for anything.

What will annoy you. Blocked merchant categories are not stated, so you cannot know in advance which shops will refuse the card. Cash-like transactions — foreign currency, crypto, money orders — may be limited. This matters more than it sounds: a card that works everywhere except travel, hotels, car hire and anything that triggers a currency or quasi-cash code is a card that fails exactly when you most want it.

Two more limits on expectations. Rewards are not stated on the card’s own pages, which after the unofficial note above means: assume none. And in this category a decline can leave a hold on your funds for several days, in some cases up to seven, which is money you have already spent and cannot access.

If something goes wrong, the route is: try the merchant first, report a disputed charge within 60 days of it posting, and the chargeback is started through your Pay3 account under card-network rules. Unresolved complaints after 60 days go to HKIAC arbitration. Sixty days is the number to note. It is not long in absolute terms but it is short relative to how long disputes take, and it is the only part of this process with a stated deadline.

The app is at app.pay-3.io, reached as a Telegram Mini App or web app. There is no stated App Store or Google Play listing, and no ratings are published — which tells you something about how you will interact with the company day to day.

What can go wrong

The honest summary: I found no official incident, and I found almost no independent reporting either. Both of those are facts about the evidence, not facts about the card.

The company’s own description is worth quoting in full, because it settles a lot at once. Pay3 Limited was incorporated in Hong Kong in 2024. It describes itself as “a fintech company, not a bank”, and delivers its services through licensed partner providers. The card issuer is named as Third National, with no country given. The licences themselves are not named on the pages I read.

No incidents: I found no official incident involving the card. What I did find is thinner than thin. Community evidence is very thin, and the few organic complaints are of a card failing to open with an error, and support reachable only via a Telegram bot or a help section. Support is listed as [email protected], a Telegram channel at t.me/pay3io, and X at @Pay3_io, with no stated hours. There is no Trustpilot page for Pay3. News is not stated either — the site mentions a Grow product “coming soon” and Autopilot “in development”, with no dated events.

Your money is not protected. This is the point I would put in bold. Pay3 states that it does not offer custody of any digital or fiat assets — the model is non-custodial. But non-custodial is not the same as insured. There is no insurance and no guarantee scheme. In a liquidation only the amount needed to repay the debt is sold. So the structure is: the crypto stays yours, and the moment you spend, the arrangement is a loan against your own holdings with nothing behind it.

A small documentation inconsistency. The card terms show a returned-payment fee of $29 in one table and $50.00 in another place. Two different numbers for the same charge in the same document. It may be an old figure left behind, but until someone confirms which applies, assume the higher one if a payment of yours comes back.

The unstated things add up. Card currency, tier differences, coin list, network list, minimum top-up, who pays gas, withdrawal fees, ATM allowance, blocked merchant categories, rewards, verification processing time, rejection reasons, shipping countries, shipping cost, replacement cost, support hours, licences, issuer country. Individually each is a small blank. Together they are the practical cost of this card: you will be finding some of them out by doing it.

One category-level reminder, because it is the failure mode that repeats. Blockchain transfers are irreversible. A deposit sent on an unsupported network, or to an address belonging to another network, can be gone. And stablecoins are not censorship-proof — Tether states it disables tokens in wallets on the OFAC sanctions list and has frozen funds tied to illicit activity.

What to take instead

Three cards I looked at alongside Pay3, on the same terms. The scores are theirs, not mine.

Sponge is the thinnest of the three on disclosure — no country list, no cost, no fees, no rewards — and it sits at the bottom on score. It is worth naming only because its funding model is the cleanest of all of them: USDC moved directly from your own Sponge wallet, on a named chain. If your priority is a card that spends exactly what you hold with no fiat layer, that simplicity is real. Everything else about it is a page you have to ask them for.

Nexo matches Pay3’s 6.3 and is a different proposition: a much larger asset list, a defined cashback ladder, and an FX fee that is stated in actual numbers rather than a range — 0.2% on weekdays in the EEA, UK and Switzerland against 0.7% at weekends, and 2% to 2.5% elsewhere. What it costs you is geography. It is for residents and citizens of selected European countries including the EEA and the UK, and that word “and” is doing real work. The physical card also needs a balance above $5,000 in digital assets and at least Gold tier. Not legal advice, just a fact worth noticing: Cointelegraph reported a 2025-era Bulgarian police raid on Nexo’s Sofia office over alleged Russia-sanctions and AML violations, with no official Nexo statement about any Russians found — a single non-official report about a company that is otherwise more transparent than Pay3.

Xplace scores highest at 7.7 and is the clearest departure in structure. Its annual fees are published and they are not small — Basic free, Silver $99 a year, Gold $249, Platinum $999 — but borrowing carries no origination fee, it accepts a named list of assets on Solana, it promises no hidden spread on stablecoin spending, and it offers 0% FX on Platinum. Cashback in Credit mode runs from 0.5% on Basic to 2% on Platinum, paid in USDC to your wallet at settlement. You pay an annual fee and buy transparency.

The choice, then, is not simply “which is best”. If you are outside Europe and want no annual fee and immediate virtual cards, Pay3 is in the running. If you are in Europe and want published percentages, Nexo’s FX disclosure is the better deal. If you will hold a balance for a year anyway and want to know every number up front, Xplace’s published fee ladder is worth the money.

Who I would recommend it to

I would recommend Pay3 to someone in a specific position: you already hold stablecoins, you can pass the identity check without trouble, you are not a US citizen, you are reasonably confident you are outside the restricted set, and what you want is a Visa that appears in Apple Pay today and in a physical wallet within the week. You spend mostly online or in your own country. You do not need an ATM. And you have internalised that this is a spend-against-your-own-crypto arrangement with no insurance behind it, funded by collateral you still own.

I would not recommend it to you if any of these are true. You want the company to hold your money — it explicitly does not. You are a US citizen, or you travel constantly and care about FX fees with a 3% ceiling and no stated combination rule. You need ATMs. You need a published list of which merchants accept you before you start. You plan to hold a large balance and find “no insurance and no guarantee scheme” uncomfortable. Or you simply want to know, before you begin, exactly which countries are excluded — because Pay3 will not tell you.

Frequently asked questions

What is the Pay3 card?

Pay3 is a collateral-based payment card: you deposit crypto as collateral, that collateral sets your spending limit in US dollar terms, and you spend through a Visa. The card exists as a virtual card immediately after application, as a physical card arriving in three to five business days, and as Apple Pay and Google Pay cards. Pay3 Limited was incorporated in Hong Kong in 2024 and describes itself as a fintech company, not a bank.

How does the Pay3 card work?

You verify your identity once in the app through Sumsub, apply for a card, then fund it. Because the card is collateral-based, your limit equals the US dollar market value of your posted collateral, not a fixed number. Funds you add stay yours in the sense that Pay3 states it offers no custody of assets, and in a liquidation only the amount needed to repay the debt is sold. That is also why the card carries no insurance.

Is Pay3 a bank, and who owns it?

No. Pay3 states plainly that it is “a fintech company, not a bank”, and it delivers services through licensed partner providers. The company is Pay3 Limited, incorporated in Hong Kong in 2024. The card issuer is named as Third National, with no country stated. The licences themselves are not named on the pages I read, so if that matters to you, it is worth asking before you fund anything.

Which countries can use the Pay3 card?

The card is open to users outside “Restricted Locations”, defined as countries under trade sanctions, export controls, or crypto and fintech prohibitions. Citizens and residents of those locations are excluded — but the list itself is not published and may change without notice. Separately, users must attest they are not a US citizen and are not OFAC-blocked, which rules out US citizens living elsewhere.

How much does the Pay3 card cost?

Issuance starts at $5 and card spending starts at $0.15 per transaction; no monthly or annual fee is stated. Currency conversion is quoted “from 1.15%”, while the foreign exchange fee for non-USD, the cross-border fee and the foreign transaction fee can each reach 3%. Fees vary by card type, currency and location, and the terms do not say whether those currency-related charges stack or replace each other.

How do I top up the Pay3 card?

You add stablecoins, or fiat into a multi-currency account that shows cash, stablecoin and card balances together. Adding funds is free and the top-up fee is 0%. What is not stated: the specific coins and networks, the minimum top-up, and who pays the on-chain network fee. That last point is the one to check — on some networks the fee can only be paid in that network’s own token.

Can I use the Pay3 card at ATMs?

Do not plan on it. The platform terms say physical cards “may support” ATM cash withdrawals, subject to partner policies, and the card terms say cash advances and balance transfers are not available. No ATM fee and no withdrawal allowance are stated. Treat ATM use as something that may not work at all rather than as a feature with a price attached.

Is the Pay3 card safe, and is my money insured?

Your crypto is not held by Pay3 — the card states it offers no custody of digital or fiat assets, which removes the counterparty risk a custodial wallet carries. But the terms are equally clear that there is no insurance and no guarantee scheme. If a liquidation happens, only the amount needed to repay the debt is sold. Two further practical points: transfers are irreversible, and Tether states it disables tokens in wallets on the OFAC sanctions list.

What happens if I want to complain or get money back?

Try the merchant first, then report a disputed charge within 60 days of it posting; the chargeback is started through your Pay3 account under card-network rules, and unresolved complaints after 60 days go to HKIAC arbitration. Withdrawals are available but no fees are stated, and the terms describe no withdrawal process. After termination, extra verification may be needed to retrieve residual balances, so close your mind to getting money back on the spot.

Is the Pay3 card worth it compared with Sponge, Nexo or Xplace?

It depends on what you are missing. Nexo scores the same 6.3 but publishes actual FX percentages and serves residents and citizens of selected European countries including the EEA and UK. Xplace scores 7.7 with published annual fees of $99, $249 and $999, named assets on Solana and 0% FX on Platinum. Sponge scores 4.9 with the thinnest disclosure of the three. Pay3’s pitch is a free top-up, an immediate virtual card, and no annual fee.

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