In 2025 there were some big developments in credit card processing that continue to reverberate into 2026. Here is Verisave's take on six topics merchants should know about because they have significant implications for processing fees in 2026 and beyond.
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CEDP
In 2025, Visa upended processing rules with the launch of its Commercial Enhanced Data Program (CEDP). The new program, which is the biggest processing rule change in the last 25 years, changed the requirements that must be met to receive the lowest interchange rates on Small Business and Commercial Cards. For years many merchants achieved discounted interchange rates by submitting fabricated data. CEDP is designed to put an end to these practices. See Verisave's CEDP Information Hub for more information.
Verisave's Take
Detailed transaction data is important because it helps prevent fraud, so pushing merchants to improve data quality is a good idea that benefits all payments system participants. The problem is the new rules are complex and the rollout by Visa was botched, confusing processors and merchants alike, many of whom are still struggling to comply with the new rules. Verisave knows merchants who are complying with the new rules who are not receiving the discounted rates, and even worse Verisave knows of processors and gateways that are focused on finding new ways to game the system with fabricated data, instead of focusing on ways to help their merchants become compliant. See Beware of Noncompliant CEDP Solutions for more information.
The Bottom Line
CEDP is here to stay and Mastercard is likely to change its rules so that they align with CEDP. Merchants who want the interchange discounts need to focus on making the changes needed to become compliant. Verisave is here to help. See Verisave's CEDP Information Hub for more information.
VAMP
The Visa Acquirer Monitoring Program (VAMP), which was rolled out in 2025, has changed the way fraud and chargebacks are measured and monitored. It replaced the Visa Dispute Monitoring Program (VDMP) and the Visa Fraud Monitoring Program (VFMP) with a new framework. It also added risk thresholds for acquirers for the first time. Merchants and acquirers who exceed the defined risk thresholds started to incur fees in October 2025. For more information on VAMP see Verisave's VAMP Overview.
Verisave's Take
Taking proactive measures to reduce disputes and fraud is good business practice. Not only does it improve customer satisfaction, but it also helps the payments system function smoothly. That said, merchants need to be alert and understand the way the VAMP ratio is calculated (see Verisave's VAMP Overview for details) so that they do not inadvertently find themselves in a position where they are incurring penalties. Merchants may also find that processors are putting more pressure on them to reduce their VAMP ratios because processors now have risk thresholds for their portfolios.
The Bottom Line
Putting operational focus on dispute and fraud reduction is good business practice. See Verisave's Tips to Reduce VAMP Penalties for suggestions on steps you can take to stay compliant with VAMP.
Proposed Visa/Mastercard Settlement
In November 2025, Visa and Mastercard announced a revised $38 billion settlement that stems from a 2005 class-action lawsuit by merchants that accused them and the banks that issue their payment cards of violating antitrust laws, causing merchants to pay excessive fees. The settlement was put forth to replace a $30 billion proposed settlement that the Court rejected in 2024. In addition to offering a reduction in interchange fees, the proposed settlement gives merchants the ability to pick and choose which types of Visa and Mastercards they want to accept, and it expands their ability to surcharge. For more details see Visa and Mastercard's Proposed $38B Settlement.
Note: This settlement follows a $5.54 billion settlement, stemming from the same lawsuit, which was approved in 2023. That settlement provides payments to merchants who accepted Visa or Mastercard between 2004 and 2019. It did not address all of the issues raised in the 2005 lawsuit, including a dispute over the rules Visa and Mastercard impose to accept their cards.
Verisave's Take
From a merchant perspective, the new settlement definitely improves upon the 2024 proposal that was rejected by the Court. Doing away with the "honor all cards rule" which allows merchants to refuse cards, such as reward cards which carry higher interchange rates, is a big concession and it is rumored that card issuers are not happy with this development. Together the interchange reduction and rule changes generate significant value for merchants, but merchant advocacy groups say the deal is inadequate. One piece of evidence they cite is the fact that in aggregate, merchants are paying more fees than ever before, but that is due in part to consumers shifting away from cash to credit cards.
The Bottom Line
Although Visa and Mastercard made some significant concessions in this new proposal, merchants still aren't happy. The implications of this settlement are huge, but don't hold your breath. Not only is it unclear if the Court will approve the settlement, but suits from large merchants who did not join the class action are still pending. We have been waiting over 20 years for this suit to be resolved and there is no guarantee that it will be settled in 2026.
Illinois Interchange Fee Prohibition Act
In 2024, the state of Illinois passed the Interchange Fee Prohibition Act, which prohibits the collection of interchange fees on sales taxes, excise taxes, and tips if a merchant elects to separate out those charges from the price of a purchase. It also prohibits participants involved in an electronic payment transaction (except the merchant) from transferring or using data from that transaction except to facilitate or process the transaction, or as required by law. In 2024, a preliminary injunction which covers nationally chartered banks, federal savings associations, and out-of-state banks doing business in Illinois was put in place. Plaintiffs have asked the court to extend that injunction so that all financial institutions, including Illinois chartered banks, federal and state credit unions and the payment card networks are exempt from the law. Oral arguments were held in late 2025. For more information see Verisave's Illinois IFPA Update.
Verisave's Take
The IFPA was passed by the Illinois Legislature in a last-minute deal as part of a larger budget bill – the Illinois Retail Merchants Association negotiated the deal when legislators capped a tax refund retailers can claim at $1,000/month. The fact that the law was not thoroughly vetted shows – it is clear it violates a number of federal statutes, which is probably the reason many other states that considered similar legislation after the IFPA was passed did not pursue it. Further evidence of the law's flaws is the fact that the preliminary injunction in place already exempts about 90% of card transactions in the state from the IFPA, according to the Electronic Transactions Association.
The Bottom Line
Even if you don't live in Illinois, you should keep an eye on this one as it has national implications. Verisave does not think the IFPA will ever be implemented. In addition to all the court action, some Illinois legislators are already working to repeal it.
The Federal Reserve & Debit Card Fees
In late 2025, contradictory rulings by two different federal courts created uncertainty regarding the validity of the framework the Federal Reserve uses to set interchange rates for debit card transactions. One ruling invalidated the framework while the other ruling upheld it. The Federal Reserve has appealed the decision that invalidated the framework. This effectively puts a hold on the Fed's 2023 proposal to change the methodology used to determine the debit card interchange fee cap, which would have lowered the cap by 30%. For more information see Regulatory Uncertainty for Federal Reserve Debit Interchange Framework and Federal Reserve Proposes Reducing Debit Card Interchange Fees. For data the Fed released in December 2025 regarding debit card processing fees see Federal Reserve's Biennial Debit Card Report Findings.
Verisave's Take
What a mess. There is no way this is going to be resolved quickly. The courts are slow in the best of times, and this will be even worse because the contradictory rulings were by courts in different federal circuits, which introduces yet another element of complexity into the mix. It is hard to believe this will all be resolved in 2026.
Processor and Issuer Consolidation
Consolidation continues, not just via mergers and acquisitions but also via SaaS companies that add payment integrations, which effectively reduce the number of processing options available to merchants. Two particularly significant consolidation events occurred in 2025 — Global Payments announced it is acquiring Worldpay and Capital One closed its acquisition of Discover. For more details see: Global Payments to Acquire Worldpay and Regulators Approve Capital One Acquisition of Discover.
Verisave's Take
Consolidation will continue throughout the payment system in 2026. This will leave merchants with fewer options and probably higher fees, as processors have raised fees post-acquisition in the past. The effects of the Worldpay acquisition will become more apparent in the second half of 2026 as the transaction is supposed to close in the first half of the year. As for Capital One's acquisition of Discover, it is still unclear what impact that will have. Will Capital One choose to follow in Visa and Mastercard's footsteps and maintain the status quo or will it wield its new market power in disruptive ways? It remains to be seen.
The Bottom Line
It is clear consolidation will continue causing upward pressure on processor fees, which makes it even more important for a merchant to proactively do all it can to optimize processor, interchange and card network fees to keep the overall cost as low as possible. Verisave is here to help.
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