
This is general information, not legal or tax advice.
Is it an interest-free loan?
A new detailer on a detailing forum asked how to sell gift cards. A friend had called them an interest-free loan. The cash does arrive early, but every card is a job you still owe, possibly years from now. Treat it as a promise, not a windfall.
The federal rule in plain terms
The rule sits in Regulation E at 12 CFR 1005.20. It covers gift certificates and store gift cards sold to consumers in a specified amount, including codes you email. The CFPB’s official interpretation covers an emailed code redeemable for a specified amount, online or in person.
What it requires:
- Five-year floor. The money on a covered card must last at least five years from the day it was issued or last loaded.
- Fees. A dormancy, inactivity or service fee is allowed only after a year with no activity. It must be printed on the card and charged no more than once a month. The FTC notes that a fee to buy the card or replace a lost or stolen one may still be charged.
- Disclosure. Fee and expiration terms must be shown before purchase and can’t be changed after the sale.
- Replacement. The FTC says a card’s printed expiration date may fall before the five-year mark. If so, the money can be moved to a replacement card at no cost.
What counts, and what doesn’t
| Card type | Federal gift-card rule? | What to put on it |
|---|---|---|
| Dollar-value card or emailed code (a set amount toward any service) | Covered | No expiry, or at least five years; any fees printed on the card |
| Paper-only certificate, value exists only on that paper | Excluded (paper form only) | Your state’s rules still apply; keep a ledger number |
| Card for a named service (“one full interior detail”) | Generally not covered (no specified amount), unless it has a dollar cap | List exactly what’s included; check your state |
| Free bonus card given with a card purchase | Excluded if labeled as promotional | “Promotional” and its expiration date on the front |
The paper exclusion applies only when paper is the sole way the certificate is issued. Printing out an emailed code doesn’t count. The CFPB’s own example is a prepaid car wash with a paper receipt code.
Your state may be stricter
The federal rule is a floor. Washington’s Department of Revenue has a guide for restaurants and retailers. It says gift certificates issued after July 1, 2004 can’t carry an expiration date, and retailers may not charge fees on them. Balances of $5 or less must be refunded if the owner asks. Check with your state’s consumer protection office or attorney general.
When prices rise before the card is used
A card sold in December may not come back until months later, after a price change.
A dollar-value card holds its face value. If your interior detail went up, the customer applies the card and pays the difference. Say so on the card. Announce the increase as you would any change. See how to raise prices without losing regulars.
A named-service card is harder. You promised the service, so honor it as sold. The federal rule generally doesn’t reach these cards. The CFPB does say a card for a service “up to” a dollar amount is covered. That doesn’t mean your state lets you change the deal. To sell packages, print the dollar value and the package it covered on the day of sale.
Price the card from the same cost floor as any job. See how much to charge for mobile detailing.
The money on your books
Keep a simple ledger with these columns:
- card number
- date sold
- amount paid
- amount used
- remaining balance
It shows what you still owe. If you take bookings and deposits online, see booking software for a one-van detailer before adding e-cards.
Now taxes. IRS Publication 538 says you generally report an advance payment for services as income in the year you receive it. Under the cash method, income counts in the year you actually or constructively receive it. Under an accrual method, you can elect to postpone the advance payment until the next year, but not beyond that year. The publication says certain gift card sales count as advance payments eligible for deferral, if requirements are met. A tax professional can tell you which method fits your business.
Cards that are never used raise a separate question: unclaimed property. Washington’s guide lists unredeemed gift certificates issued before July 1, 2001 as unclaimed property. It says most property is presumed abandoned after three years. Each state sets its own rule, so check yours before you write off old balances.
If a card buyer later disputes the charge, the same records help. See chargeback paperwork for detailers.
A clean setup
- Sell dollar-value cards with no expiration date and no fees.
- Print “Applies toward any service at current prices” and a way to check the balance.
- Number every card and log it the day it’s sold.
- Label any free bonus card “Promotional” and put its expiration date on the front.
- Check your state’s gift card and unclaimed property rules once a year.
How we check facts: methodology.
Sources
Based on 7 sources · How we price
Checked 2026-10-09. This page is general information, not legal or tax advice. Community discussions are paraphrased for the question only; they are not factual sources.
- eCFR, 12 CFR 1005.20, Requirements for gift cards and gift certificates: ecfr.gov/current/title-12/chapter-X/part-1005/subpart-A/section-1005.20
- Consumer Financial Protection Bureau, Regulation E § 1005.20 with official interpretation: consumerfinance.gov/rules-policy/regulations/1005/20
- Consumer Financial Protection Bureau, Regulation E official interpretation of § 1005.20: consumerfinance.gov/rules-policy/regulations/1005/interp-20
- Federal Trade Commission, FTC Has Gift Card Tips for Holiday Buying (Nov. 2010): ftc.gov/news-events/news/press-releases/2010/11/ftc-has-gift-card-tips-holiday-buying
- Washington State Department of Revenue, Unclaimed property (restaurants and retailers of prepared food guide): dor.wa.gov/education/industry-guides/restaurants-and-retailers-prepared-food/unclaimed-property
- IRS, Publication 538, Accounting Periods and Methods: irs.gov/publications/p538
- Community discussion (a new detailer asks how to sell gift cards): reddit.com/r/AutoDetailing/comments/1ia4qwt


